Militant LNER Ticket Inspectors - Split Season Tickets

[sc597]

Hello All, as previously discussed on here I have split season tickets from Peterborough to London Terminals, split at an intermediate station that the LNER trains don't call at, but as per NRCoC 14.2 this is a valid thing to do if one's a season ticket (just checked and the wording is still the same for the Dec 2019 issue).

Most of the inspectors are fine but there are a couple that repeatedly make a fuss about the combination and in particular one that demands to take photos and even take the tickets away to investigate them. I agreed to this previously but am I within my rights to refuse to let inspectors take pictures (GDPR?!) and take my tickets away to further investigate them? I'm also whacking in (another) complaint to LNER about it but would appreciate thoughts on whether I can refuse the photos and taking tickets away, both of which I find intrusive and don't seem to be allowed within the rules.

 

[transmanche]

Why do you think that GDPR might prohibit a ticket examiner from taking a copy of your ticket? Taking a copy of something so its validity can be checked seems to be a reasonable and proportionate thing to do.

 

[yorkie]

Hello All, as previously discussed on here I have split season tickets from Peterborough to London Terminals, split at an intermediate station that the LNER trains don't call at, but as per NRCoC 14.2 this is a valid thing to do if one's a season ticket (just checked and the wording is still the same for the Dec 2019 issue).

Most of the inspectors are fine but there are a couple that repeatedly make a fuss about the combination and in particular one that demands to take photos and even take the tickets away to investigate them. I agreed to this previously but am I within my rights to refuse to let inspectors take pictures (GDPR?!) and take my tickets away to further investigate them? I'm also whacking in (another) complaint to LNER about it but would appreciate thoughts on whether I can refuse the photos and taking tickets away, both of which I find intrusive and don't seem to be allowed within the rules.

You probably can't stop them doing this, however it is worth writing to LNER to ask what data protection measures they have in place. LNER are subject to FOI, don't forget!

For example, do they have work issued cameras, how are the images stored/transmitted, what are their data retention policies, etc.

Why do you think that GDPR might prohibit a ticket examiner from taking a copy of your ticket? Taking a copy of something so its validity can be checked seems to be a reasonable and proportionate thing to do.

An image of a Season ticket containing a photo should only be stored on a device if it is necessary to do so, and only for as long as there is a valid purpose, and only if it is secure, etc etc.

I'd argue that it should never be necessary in the situation described as no photo is needed to check the validity if the inspectors have had anything like the appropriate level of training.

A Season ticket with photocard is considered sensitive personal data.

 

[transmanche]

An image of a Season ticket containing a photo should only be stored on a device if it is necessary to do so, and only for as long as there is a valid purpose, and only if it is secure, etc etc.

I was taking that as a given.

I'd argue that it should never be necessary in the situation described as no photo is needed to check the validity if the inspectors have had anything like the appropriate level of training.

I'd agree, in this instance, as we're not talking about anything obscure. But in general terms, taking a copy of a ticket seems a reasonable way to for a ticket examiner to verify the validity of a ticket, without delaying the customer. Even if only to educate themselves so they improve their knowledge for the future.

A Season ticket with photocard is considered sensitive personal data.

Agreed. But I see no reason for a copy of the photocard to be taken. Only the ticket.

 

[yorkie]

Agreed. But I see no reason for a copy of the photocard to be taken. Only the ticket.

Agreed

 

[sc597]

Thanks all, I will query the data protection - yes it was the retention I was interested in, particularly with regard to the photocard.

 

[yorkie]

Thanks all, I will query the data protection - yes it was the retention I was interested in, particularly with regard to the photocard.

Yes; I was thinking from your reaction that they must be doing this, as I can't imagine there being such an issue otherwise. I see no justification for taking a photo of the Photocard. It's not relevant, which makes it unlawful, in my opinion (having just done some training on this subject yesterday as it happens!)

 

[221129]

I agreed to this previously but am I within my rights to refuse to let inspectors take pictures (GDPR?!) and take my tickets away to further investigate them? I'm also whacking in (another) complaint to LNER about it but would appreciate thoughts on whether I can refuse the photos and taking tickets away, both of which I find intrusive and don't seem to be allowed within the rules.

If a zero fare or receipt is issued then you cannot refuse to hand over your season ticket for investigation. After all it remains the property of the railway.

 

[yorkie]

If a zero fare or receipt is issued then you cannot refuse to hand over your season ticket for investigation. After all it remains the property of the railway.

Though they would only be entitled to do this if they had sufficient grounds to do so.

 

[furlong]

If a zero fare or receipt is issued then you cannot refuse to hand over your season ticket for investigation. After all it remains the property of the railway.

On what basis do you believe the ticket is the property of the railway and not the purchaser?
(Hint read the current Conditions of Travel, not an old version. They only seem to provide authority to withdraw a ticket that *is* invalid i.e. as a matter of fact. Mere suspicion isn't enough.)

 

[yorkie]

I understand LNER have been contacted, so I suggest we pause this discussion until they have responded.