GTR clearly don’t agree. They’ll gladly accept a driving licence provided the name matches that on the ITSO card.
Sure. GTR say it's ok. On GTR services. But that limits you to using a potentially any permitted season ticket only on GTR services as the T&C of using that smart card with a drivers licence only applies to use on a GTR service. GTR states on their website:
"For season tickets held on your Key Smartcard, you may need to produce identification to prove that the ticket you hold on your smartcard belongs to you. Suitable forms of identification include a pink photocard (which can be obtained from ticket offices), a passport or driving licence. If you are using your Key Smartcard on another operator’s services, you will need to obtain a pink photocard if you don’t already hold one."
So to get full use of your ticket across all operators you will still need a railway issued photocard.
Of course a face changes over time - Apple made a point of teling us all how Face ID monitors and learns precisely those small changes. Still doesn’t change the fact that HM Border Force will happily accept the photo on a ten year old passport.
In point of fact HM Border Force would probably NOT accept a Passport of a person who's face has changed drastically over nearly 10 years. Not without detaining that person for a few hours and investigating to confirm or deny that persons ID. (I have personally experienced this when travelling back into the UK on my previous UK Passport.)
If you’re that fussed, take a photograph of the proof of ID. As far as I’m aware, there is nothing in GDPR that stops you from doing this where there is a genuine need for the company to hold that data, of which investigating fraud would be a genuine need.
The GDPR primarily covers processing and storing of personal information. 'Looking at data provided by a customer for proof of ID' would not count as processing or storing information so has no relevance to the GDPR.
Again, if a person were so paranoid that they could not bare to allow a rail conductor to see their driving licence, then the photocard option would be fine.
First up, not everybody is going to be comfortable showing a complete stranger their Driving License when it contains personal details such as date and place of birth, address etc. A vulnerable person of any age might quite rightly be concerned as to what could worse case happen to them with that information revealed to somebody they don't personally know.
Second, If a photo of a drivers licence contains legible information of a personal or private nature - such as the info that many have already stated is the "Gold Standard" of proving your address or ID in the UK. It therefore contains the sort of information that an identity thief would be happy to get hold of. That would probably come under the GDPR. If someones data can be misused to that persons detriment the GDPR surely applies. The format of that data (a photo in this case) would be irrelevant. The key phrase used in GDPR legislation is "Personally Identifiable Information".
A Drivers License cannot be both the gold standard of UK ID AND immune to being protected under the GDPR legislations.
GDPR also requires that companies and individuals who hold or handle that data do so in an accountable way. There would need to a record of who has what data at the TOC and who it is shared with. That data must also be stored securely. Ticket Inspectors/Conductors running around with old photos of people's drivers licenses on their phones would definitely violate that principle.
The BTP officer you referred to would probably have gladly relieved the passenger of that driving licence regardless if it clearly did not belong to them....
They surely would have. But it isn't always possible to get any BTP or any Police to attend a ticket dispute. If there wasn't a Police Officer present I would not have been able to take and retain their Drivers License. But I was allowed to retain the photocard.
The only reason in that specific situation why I requested the BTP was because I had doubts as to the details I was given by the passenger. (Before the BTP arrived I had been given 3 different names and addresses. None of the addresses could even be verified as actually existing) It was therefore a reasonable request for BTP to establish their actual details. Turned out they were not only known to the Police, had an open arrest warrant out - they were also carrying a number of stolen wallets, phones and class A drugs. Sure, the fare evasion was a small fry charge added on. But because of the evidence retained they were found guilty of it and a hefty fine was added on to make their days in court extra special.
I also mentioned that those were just 2 reasons I could come up with on the fly. Other reasons could include (but not limited to):
The Photo on a Drivers License is smaller and contains security details to hinder forgeries. This makes it harder to look at, at a glance. Hindering it's usefulness to rail staff carrying out ticket checks.
Most people don't keep their season tickets in their main wallet. They keep them in a travel wallet - commonly a Railcard/Season Ticket wallet supplied by a TOC. Forgetting or losing your Ticket doesn't often mean they have forgotten or lost their actual wallet.
Many people (myself included) don't even like carrying important photo ID around out of the house for many reasons. I personallu don't want to risk losing it and having to mess aroumd reporting it as lost or stolen and applying for a replacement. I only take my DL or Passport out and about If I have a specific reason that requires it.
If you lose your ticket wallet with the drivers license - how long will it take to get a replacement Drivers License issued and delivered? Is it quicker than the time it takes someone in the booking office to process a Lost or Stolen Season Ticket form and slap a new photocard together? (Overnight at most/same day at many ticket offices)
I could go on, but clearly this is one of those situations where I'm not going to change my mind.