Privacy and Cookies

This page displays our current Privacy and Cookie Policy. Last updated May 2018.

Privacy Notice

GDPR – General Data Protection Regulations

On the 25th May 2018 new legislation comes into force. GDPR is a regulation in EU law on data protection and privacy for all individuals within the European Union. In the UK GDPR will replace the Data Protection Act 1998 and seek to give people more control over how organisations use their data.


As your employer, the Company needs to keep and process information about you for normal employment purposes. The information we hold and process will be used for our management and administrative use. We will keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately, during the recruitment process, whilst you are working for us, at the time when your employment ends and after you have left.

This includes using information that enables us to comply with:-

  • Employment contracts
  • Legal requirements
  • Pursue the legitimate interests of the Company
  • Protect our legal position. 

If you do not provide this data, we may be unable in some circumstances to comply with our obligations and may face exclusions from business processes. We will tell you about the implications of that decision.

What we do

As a company providing public transportation Edinburgh Trams is obliged to use your personal data under a number of lawful conditions. This includes using your data under contract to fulfil our duties as an employer such as for example, to administer holiday and sickness leave or payroll.

In some circumstance we may ask for your consent to use your data for social events that you may wish to attend. In other circumstances we may be obligated to share your data under juridical methods for law-enforcement purposes.

Edinburgh Trams will always treat your data with dignity and respect upholding your rights as a Data Subject.

What we hold

Much of the information we hold will have been provided by you, but some may come from other internal sources, such as your manager, or in some cases, external sources, such as referees, or the DVLA or HMRC.

The sort of information we hold includes

  • Your application form and references
  • Your contract of employment and any amendments to it
  • Correspondence with or about you, for example letters to you about a pay rise or, at your request, a letter to your mortgage company confirming your salary
  • Information needed for payroll, benefits and expenses purposes
  • Contact and emergency contact details
  • Records of holiday, sickness and other absence
  • Information needed for equal opportunities monitoring policy;
  • Licensing requirements and records relating to your career history, such as training records and appraisals.
  • Other performance measures and, where appropriate, disciplinary and grievance records
  • Proof of ID and Proof of Right to Work in the UK.

Where necessary, we may keep information relating to your health, which could include reasons for absence and GP reports and notes. This information will be used in order to comply with our health and safety and occupational health obligations – to consider how your health affects your ability to do your job and whether any adjustments to your job might be appropriate. We will also need this data to administer and manage statutory and company sick pay.

Where we process special categories of information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, biometric data or sexual orientation will be done with the minimum amount of data under the contract of employment. In addition, Edinburgh Trams may have to share this data under conditions of legislation or in your vital interests.

Where we are processing data based on your consent, you have the right to withdraw that consent at any time.

In addition, we monitor computer and telephone/mobile telephone use, as detailed in our Computer Usage and Information Security Policy.Edinburgh Trams make significant use of image recording equipment like CCTV or voice recording equipment, which can be used for staff monitoring and safety.


Other than as mentioned below, we will only disclose information about you to third parties if we are legally obliged to do so or where we need to comply with our contractual duties to you, for instance we may need to pass on certain information to Pension or Health insurance schemes.

We may share information about you to other group companies for purposes connected with your employment or the management of the company’s business.

We may also transfer your data to destinations outside of the EEA, but this will be done only with appropriate legal safeguards.

We do not use automated decision making.


Your personal data will be stored for the period of your employment and up to 6 years plus the current year after your last date of employment. Unless there is are lawful reasons to hold your data longer, e.g. pension data.A copy of the Retention Schedule can be requested from the Data Protection Officer.

If in the future we intend to process your personal data for a purpose other than that which it was collected we will provide you with information on that purpose and any other relevant information.

Your rights

Under the General Data Protection Regulation (GDPR) you have a number of rights with regard to your personal data.

  • You have the right to request from us access to and rectification or erasure of your personal data,
  • Right to restrict processing,
  • Object to processing as well as in certain circumstances the right to data portability
  • You can also make a SAR ( Subject Access Request ) which means requesting information on the information that is held about you

If you have provided consent for the processing of your data you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

If you have data protection complaints, in the first instance you should lodge any complaint with Edinburgh Trams Data Protection Officer, but you also have the right to lodge a complaint to the Information Commissioners’ Office if you believe that we have not complied with the requirements of the GDPR with regard to your personal data.

Identity and contact details of data controller

Edinburgh Trams Limited is the data controller of your personal data while employed for the purposes of GDPR.

To make a subject access request, please complete this form and send to the Data Protection Officer at

For alternative ways to contact us, please click here.


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Edinburgh Trams Ltd and our agents may use cookies to count the total number of unique users who are accessing the site over a particular period of time. This information will never be shared with a third party, and is only used to make our systems more efficient. Some content on the Website and/or Services might be served by third parties who may serve cookies on your browser as well, for instance to gauge the effectiveness of a particular piece of content. Please note that this will not enable third parties to access your personal details.

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