Privacy Notice for the Inclusive Cycling Experience

For details on Cycling UK’s other data processing please see our main privacy policy.

Updating the Notice

We may modify this Notice at any time. We will endeavour to update you to any significant changes to this Notice. This Notice was last updated in July 2024.

Data controller and contact details

The Cyclists Touring Club (trading as Cycling UK with company number 25185 and registered as a charity in England and Wales with charity number 1147607 and in Scotland with charity number SC042541) is the data controller of your personal data.

If you have any questions about this Notice, or if you would like to exercise any of your legal rights in respect of your personal data, please contact our Data Protection Officer using the following details:

• Email: dpo@cyclinguk.org
   
• Post: FAO Data Protection Officer, Parklands​, Railton Road, Guildford, Surrey GU2 9JX

Motability Foundation

The Inclusive Cycling Experience is funded by a grant from the Motability Foundation (Motability). Cycling UK will share information with Motability in the form of case studies and survey data to allow Motability to monitor and evaluate the Scheme and to support Motability’s charitable objectives in assisting disabled persons in connection with transport.

Please note that Motability (and not Cycling UK) is the data controller for personal data that motability processes in connection to the Scheme. The Motability privacy policy can be viewed here Privacy | Motability Foundation.

If you have any questions in respect to Motability’s processing please contact Motability using the details in the Motability privacy policy.

How we collect your information

We may collect your personal information:

• from the information you provide to us (or someone else provides on your behalf) when you (or they) fill in the forms to register for a loan or taster session, including on the Cycling UK website
   
• when you correspond with us by phone; email, or by other means in respect to the Scheme
   
• From the information you provide to us when you complete any of the surveys we send to you for monitoring and evaluation purposes.  
   
• From GPS tracking devices we may attach to the cycles that are activated in the event of a reported theft or non-return of the cycle. These tracking devices provide us with geo-location data to enable the recovery of our cycles  
   
• from our Scheme partners who assist us in operating the Scheme such as Wheels for Wellbeing. Scheme partners provide us with information about your use of the Scheme and may assist us in collecting survey information on our behalf or advising Cycling UK on analysing survey data

The types of information we collect and our legal basis for using your information

We may collect and process the following personal information about you:

• when you use our booking system we collect your name, postcode, contact details (address, email address and phone number), emergency contact details, gender, whether you are over 18, your cycling experience and details concerning your loan or attendance at our taster sessions (including any mobility/access requirements, whether you identify as disabled and whether you are taking any medication). We will process this information because it is necessary for the performance of our user agreement with you, for our legitimate interests in helping us understand your cycling activity and what you would like to get out of the Scheme, or to take steps at your request prior to entering into the user agreement with you, and to comply with our legal duty of care
   
• if you are applying to loan a cycle or take part in a taster session as part of our dedicated support for disadvantaged groups then we will collect information and evidence concerning any relevant physical and mental health conditions. We process this information for our legitimate interests in confirming your eligibility for the Scheme. Where we process information concerning physical and mental health conditions for this purpose we will do this with your explicit consent
   
• if you are applying to hire an adapted cycle or  participate in a taster session with adapted cycles then we will collect information concerning any disabilities or access requirements. We collect this information because it is necessary for the performance of our user agreement and to comply with our legal duty of care
   
• we will analyse the information collected by surveys for our legitimate interests to improve our operations and the Scheme and to research accessible cycling. Where this information contains health information or information about race or ethnicity then our legal basis is that we process this information for substantial public interest reasons in identifying equality of opportunity and treatment with a view to enabling such equality to be promoted
   
• we may use your name, image and details of your participation in our publicity materials which promote the Scheme and Cycling UK’s charitable activities. Our legal basis will be our legitimate interests in promoting the Scheme and Cycling UK’s work, although we will obtain your consent where appropriate
   
• You will be asked to complete surveys at various times. Your responses will be used to evaluate the effectiveness of the scheme. Your contact details (name, email address and telephone number) will be used to recontact you for the follow-up survey and to invite you to take part in interviews and focus groups. We are also collecting the following demographic data as part of our surveys:
   
  • Gender
  • Postcode
  • Physical and mental health conditions
     
• Your demographic data will be used for research and statistical purposes only
   
• We use geolocation data from our tracking devices to recover stolen or non-returned cycles. Our legal basis for this processing is our legitimate interests in recovering our property and complying with our legal obligation to assist the police. These tracking devices are only activated in the event of a cycle's theft or late return and do not track your use of the cycle otherwise.

Who we share your information with  

Information processed in respect to the Scheme is shared with:

• Motability who receive the information identified in the section above that we collect from you for the purpose of monitoring and evaluating the Scheme.  
   
• our Scheme partners who will receive information about bookings so that they can deliver the Scheme in accordance with our Scheme user agreement.  
   
• Bike Rent Manager: We use Bike Rent Manager to handle your booking. Bike Rent Manger is an inventory and reservations system that allows us to manage your booking securely.  
   
• our insurers where this is required (for example, we may need to share your information in the case of an accident) to comply with our legal obligations or to exercise or defend a legal claim
   
• Anonymised data may be shared or published for reporting purposes.  

Legal obligations

We process your personal data for our compliance with our legal obligations including for charity regulatory reporting requirements, to report crimes and serious incidents, and to comply with our legal duty of care. In this respect and only if required, we will share your data with the Charity Commission, the police and other competent authorities.

Direct marketing and consent

We also process your personal data where we have your specific consent to do so (for example, where we have sought and obtained your consent to send you direct marketing by email. If you have given your consent and you wish to withdraw it, please contact us using the contact details set out above or click the “unsubscribe” link in the emails we send.

How long your information is kept

We will retain your personal data for as long as is required for legal purposes and our legitimate business purposes after the termination of our agreement with you. In particular:

• in relation to personal data relating to your use of the Scheme, we will retain that data for a period of seven years after the user agreement has concluded in case any legal claims arise out of your use of the Scheme
   
• we will retain your details on our marketing database until you inform us that you no longer wish to receive our marketing communications. However, where you do unsubscribe from our marketing communications we will keep your details on a suppression list to ensure that we do not send you information you have asked not to receive
   
• survey data contained for research and archiving purposes may be held indefinitely subject to appropriate safeguards such as security measures and pseudonymisation where practicable  

Your rights

Under UK data protection law you have the following rights in relation to our processing of your personal data:

• to obtain access to, and copies of, the personal data that we hold about you
   
• to require us to correct the personal data we hold about you if it is incorrect
   
• to require us to erase your personal data in certain circumstances
   
• to require us to restrict our data processing activities in certain circumstances (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal)
   
• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for transmitting that personal data to another data controller
   
• to object, on grounds relating to your situation, to any of our processing activities where you feel this has a disproportionate impact on your rights
   
• to complain about the processing of your data to the Information Commissioner’s Office (ICO), although the ICO recommends that you first try and resolve the complaint with us  

Please note that the above rights are not absolute, and we may be entitled to refuse your requests where exceptions apply.