The nine Dutch public transport operators (Arriva, Connexxion, EBS, GVB, HTM, Keolis, NS, Qbuzz and RET. Seeovpay.nlfor the latest listing.) and Translink are together facilitating an additional option for travelling by public transport: purchasing a (Transport) Ticket by checking-in and checking-out using your Debit Card.
For the Debit Card we are doing this in collaboration with a number of payment services (Maestro, Mastercard, VPAY and VISA. See ovpay.nl for the latest listing.). These payment services activate your Debit Card with a public transport travel function in the Netherlands. You pay for your journeys via the Bank Account associated with your Debit Card.
If travelling by checking in and out using your Debit Card, you and GVB enter into a transport agreement to which the General Terms and Conditions of Urban and Regional Transport apply. When using your Debit Card the ‘OVpay Check-in/out Conditions Using your Debit Card and Credit Card’ apply.
Personal data
As soon as data can be related directly or directly to a person, it is referred to as Personal data. Examples of Personal data are your name, (email) address and date of birth. Your travel data or user name can also be considered Personal data.
The Processing of your Personal Data is necessary when checking in and checking out with your Debit Card. It lets you travel and pay on public transport in GVB. GVB and Translink can also provide you with services.
If you do not want GVB and Translink to have the necessary Personal Data, you will not be able to travel and pay with your Debit, and have to use another regular (Transport) Ticket.
The processes have been designed on the basis of Privacy by Design. This means that Translink and the Public transport operators have designed and set up the systems in such a way as to protect your privacy as a passenger as much as possible.
Pseudonymisation, re-identification and use of tokens
Immediately after you have checked in, the unique identification number, the 'PAN' of your Debit Card will be Pseudonymised. (The abbreviation PAN stands for Primary Account Number. This is the unique number of your Debit Card. It allows for identification of your Debit Card.) Each Debit is allocated its own unique number, a so-called token. These unique tokens are used for various purposes including travel, payment, service, inspection and overview reports.
Translink has a central administration system where, among other things, Translink registers on behalf of the Public transport operators Tickets, calculates the price that a journey costs, and keeps track of the total amount for which you have travelled that day. The system allocates each Public transport operator its own unique identification numbers for the tokens, so that the Public transport operators have no mutual insight into the travel patterns of passengers using a Debit Card with other Public transport operators.
Pseudonymised data cannot be traced back to your Debit Card details without additional information. This Pseudonymisation is a measure to reduce the risks for you as traveller in relation to the Processing of your Personal Data. There is a risk, however, that by combining this with other data, an organisation may still be able to identify which Debit Card belongs to the pseudonym. This may make it possible to review the travel history of a Debit Card. The Public transport operators and Translink have come to arrangements to prevent the risk of re-identification.
Glossary
When travelling using your Debit Card, we may use terms with which you are not (yet) familiar. For your convenience, we have listed these terms and their meanings.
App: a mobile application developed and offered by a Public transport operator or Public transport operators and Translink jointly (OVpay) that allows Passengers with a Debit Card to create, consult their online account, link the Debit Card to it, and thus, for example, to easily view their travel transactions and payments and submit service requests. Use of an App is subject to the terms and conditions of use of the relevant App.
AVR-NS: the terms and conditions of NS (general terms and conditions for the carriage of Passengers and hand luggage of Nederlandse Spoorwegen)
Bank: a financial institution that provides payment services and holds the Bank Account to which the Debit Card used by the Passenger on public transport is linked. This also includes a credit card company which as a financial institution is offering payment services and which has issued the credit card.
Public transport operator(s): the Dutch public transport operators listed on the OVpay.nl website that accept the Contactless OV payment described in these Terms and Conditions, as a method of payment for use of their transport services.
Controller: a natural or legal person, a government agency, a service or another body that, alone or together with others, determines the purpose of and means for Processing Personal Data as defined in the GDPR.
Debit Card: a contactless card issued by the Bank (physical or digital on a smart device such as a smartphone or smartwatch) that the Passenger uses and pays for public transport by checking in and out at designated card readers at stations, stops and in vehicles.
General Terms and Conditions of Urban and Regional Transport: the General Terms and Conditions for the use of public urban and regional transport by bus, tram, light rail, metro and regional public transport by train.
Joint Controller: If two or more Controllers jointly determine the purposes and means of the Processing, they are Joint Controllers as defined in the GDPR.
Payment reference number: this is a code comprising a combination of fourteen letters and numbers, created uniquely for each payment. This code is linked to the amount that is debited from your Bank Account when paying with a debit Card.
Personal data: any information regarding an identified or identifiable natural person as defined in the GDPR.
Processing: an operation or set of operations relating to Personal Data or a set of Personal Data, whether carried out by automated processes or not as defined in the GDPR.
Processor: a natural or legal person, a government agency, a service or another body that Processes Personal Data on behalf of the Controller as defined in the GDPR.
Pseudonymisation: the Processing of Personal Data in such a way that the Personal Data cannot be linked to a traveller without the use of additional data, provided that this additional data is stored separately, and technical and organisational measures have been taken to ensure that the Personal Data is not linked to an identified or identifiable traveller as defined in the GDPR.
Technical Debit Card data: this technical data consists of the numbers of the Debit Card , namely the PAN, the PAN serial number, and the validity date of the Debit Card. The PAN is a unique Debit Card identification number. The PAN serial number is contained in the chip of the Debit Card and is not visible.
(Transport) Ticket: the Ticket that provides valid access to the train, bus, tram and metro and that has been purchased by the passenger by checking in for each journey with GVB with the Debit Card used to travel. A (Transport) Ticket is only valid if it meets all the requirements set out in the General Terms and Conditions of Urban and Regional Transport or AVR-NS (in case of travelling with the NS).
Translink: Trans Link Systems B.V., having its registered office and principal place of business in Amersfoort.
Travel day: the period which starts at 00.00 hour and ends next day at 03.05 hour.
How does travelling and paying with a Debit Card work?
A. Travel
When checking in with your Debit Card, the card reader will read the technical data. Here we check whether the Debit Card can be used to travel, and will inform you accordingly via the card reader. Holding your Debit Card at a card reader is called a “tap”.
If you are able to travel using a Debit Card, personal data will be sent to Translink when you check in and out using the card readers of the Public transport operator with which you are travelling. In addition to the technical details of your Debit Card, this includes the date, time and stop or station where you boarded or alighted. Translink records all check ins and check outs, constructs all the trips made and calculates the trip fares. Your journey is compiled and your fare is calculated using this information as well as, if applicable, additional information on products and profiles granting you a discount.
To be able to use the discount profile ‘age discount at urban and regional transport’, you have to create an age profile in the OVpay app by providing your name, date of birth and photo. If you do not want GVB and Translink to have the necessary Personal Data, you will not be able to use age discount at urban and regional transport.
First time travelling with your Debit Card
The first time you check in with your Debit Card, an automatic check is made to determine whether that Debit Card is suitable for travel. This also occurs if you have not used the Debit Card in question for travel for 14 days, and then check in again.
Translink will also check at the Bank that holds your Debit Card if the card has been blocked. If blocking is the case, the Public Transport travel function of the Debit Card will then be blocked (temporarily), and you will not be able to use it for travel. This is a decision of the Bank. The Public transport operators and Translink cannot change this.
Checking the validity of your Debit Card
Every time you check in with your Debit Card, an automatic check will be made against a deny list at Translink to ensure that the Debit Card has not been blocked (temporarily). The deny list is managed in by Translink and distributed to Public transport operators. A Debit Card will be added to the deny list by Translink if:
the Debit Card is an alert list of the Bank, e.g. because it is listed as stolen or missing;
settlement for the Debit Card has not been made for the use of public transport, e.g. because the balance or spending limit on your Bank Account was insufficient at the time of settlement;
A product or profiles granting you a discount is used while not respecting the applicable conditions.
B. Paying
When checking in and out with a Debit Card, Translink calculates the fare for the journeys you make. Translink settles in corporation with EMS (European Merchant Services B.V., www.emspay.com) and your Bank the payment for the trips made by you. During the night following the day on which you travelled, the amount due for all the journeys you made in one day is presented in one sum to EMS and your Bank.
To process the payment, Translink provides the Technical Debit Card details and the Payment reference number to the Bank.
Upon successful payment, you can see the amount debited on your (digital) account statement. You will receive a unique Payment reference number for each day you travelled, on your (digital) account statement. This Payment reference number is created uniquely per daily payment and is preceded by the letters ‘NLOV’. You can find your digital account statement by logging in to your secure Banking environment.
This means that if you share your Payment reference number and related amount with another person or organisation, this person or organisation can get insight in the trips made by you.
In contrast to aforementioned, the amount due for the journeys made will de debited during the Travel day, instead of during the night following the Travel day, if the amount surpasses a predetermined limit as set by the Public transport operators. The amount due for all journeys will then directly be debited against your balance or spending limit. After a successful payment any other journeys you will make will be presented to the Bank during the night following your Travel day, unless the predetermined limit will be surpassed again.
Summary reports
All Public transport operators receive daily summary reports from Translink in order to check the accuracy of their own transactions and payments, to detect and correct potential mistakes and to safeguard the integrity of the public transport system. These are reports on transactions (such as check-in, check-out or failed tap), journeys (combining a check-in with a check-out) and payments relating to the specific Public transport operators. Translink ensures that GVB and the other Public transport operators receive daily all payments made for all travels made by Debit Cards.
An unsuccessful payment
If payment is unsuccessful, for example because the balance or spending limit is too low, we will block the travel function associated with the Debit or Credit Card temporarily. You can then no longer travel with your Debit or Credit Card until the outstanding amount has been paid.
Translink may issue repeated payment requests to debit the amount due from your account or spending limit within a period of 62 calendar days. The (temporary) block will be lifted if the payment is successful.
During this period as well as afterwards as a traveller you can also pay the outstanding amount yourself. To do so, you have to offer your Debit or Credit Card to a card reader of a Public transport operator. Via Translink a payment request will be made to your Bank or Credit Card Company. You can also pay the outstanding amount in the Ovpay app via your account. Via EMS a payment request will be made to your Bank or Credit Card Company. If the payment succeeds for one of those methods, you will then be able to travel again with your Debit or Credit Card approximately 15 minutes later.
(Temporary) block on travel use
The (temporary) block on using a Debit Card to travel can be checked by offering your Debit Card to a card reader of a Public transport operator and pay notice to the notification on the display or by contacting OVpay Customer care.
While any travel use of the Debit Card is blocked, you can of course always use another regular (Transport) Ticket for travelling by public transport.
C. Service
We do understand that you may have questions about a journey, invoiced costs or a missed check-in or check-out. Or perhaps you’d like to see the previous journeys you have undertaken. You can view and request (parts of) your journeys in the GVB App or via the GVB Customer care. You can also view and request (parts of) your journeys through the OVpay website, OVpay App (The OVpay app has its own privacy statement which is available in the OVpay app and at the OVpay website.) and OVpay Customer care.
For us to help you, you will need to have for your Debit Card the Payment reference number in combination with the corresponding amount of your account debit. We do not know your debit card number, nor can we search your IBAN.
App and website
Within both the GVB App and the OVpay App, you can link one or more of your Debit Cards to the App. You can do this in various ways. You first create an account with your own password. Firstly, you can enter your Payment reference number and corresponding amount in the GVB app or Ovpay app. This however only works within 31 days of travelling and when you made a contactless payment for your travel. In the Ovpay app you can also enter your PAN (PAN: this abbreviation stands for Primary Account Number. It refers to the unique card number of your Debit Card and which is used to identify your Debit Card.) and expiration date of your Debit Card at your online account and then use your Debit Card for travelling. As a third way, you can also enter your IBAN and expiration date of your Debit Card at your online account and then use your Debit Card for travelling within 60 days.
Via your online account it is amongst others possible to check if you did check-in and/ or check-out, to view the fare for travels you made and to also view your payments, payments status and any contingent blocking of your Debit Card. In the Ovpay app you can also correct any missed check-ins or check-outs and pay for any outstanding amount for travelling.
Among the items you can view in the OVpay app is all the travel history of the journeys you have made in the past 18 months using your Debit Card for all public transport services. In your account of a Public transport operator (web or App) you can only view the journeys you made with that Public transport operators using your Debit Card, also for the past 18 months. In the OVpay app, you can also set to receive notifications when checking in and checking out and in the Ovpay app also for any outstanding amount.
For your Debit Card, you can on the ovpay.nl website, with a Payment reference number and corresponding amount, view the journeys relating to that specific payment.
Customer care
Questions about travelling with a Debit Card can be put to the Customer care of GVB or the OVpay Customer care. Customer care employees cannot view your Debit Card details, or the details of your payment account.
A Customer care representative will always ask specifically for your details if this is necessary in order to answer your questions. The Customer care staff may ask for your Payment reference number and the corresponding debit amount, depending on the questions you ask.
Cross Service
The Public transport operators and Translink have signed mutual agreements so that GVB can also help you with questions about a journey with other Public transport operators. It has been agreed that you may contact the Customer care services of any Public transport operator with questions concerning all the journeys and transactions you have made over the past 62 days (by phone or at a service desk). Questions about a missed check-in or check-out can be put to the Customer care of OVpay. The Customer care staff may ask for your Payment reference number and the corresponding debit amount, depending on the questions you ask.
D. Inspection
Everyone using public transport must have a valid Ticket. If you check in with your contactless Debit Card, your Transport Ticket has been linked to your Debit Card via a registration at Translink. Special detection inspectors (‘BOA’ in Dutch) conduct regular checks in the vehicles/carriages and at stops and stations, to ensure that passengers have a valid Ticket. This includes conducting checks on the validity of you discount product and discount profile. If a ticket inspector wishes to check your Ticket, you must present your Debit Card to the inspector’s ticket reader.
To enable the inspector to provide you with courtesy and/or service, the inspector will ask your specific permission to do this. The inspector can then view the last ten actions involving the use of your Debit Card for public transport on their device (up to a maximum of 62 days ago). This data is displayed on the device for a maximum of five minutes, but will disappear earlier if another Debit Card is held against the card reader.
When using a discount product or profile at your Debit Card, then this will be visible at inspection for the BOA. This product or profile is however only visible when these are applicable for your current journey. In all other cases, this product or profile will not be visible for the BOA.
If the data provided by you for the discount product or profile are not correct, the BOA can block this discount product or profile. You are then unable to further use it. At the OVpay app or via OVpay customer care you can correct your data after which you are again able to use the discount product or profile.
Basis for the processing
When you check in and out with GVB using a Debit Card, the basis for the Processing of Personal Data is the performance of an agreement. This is a transport agreement to which the General Conditions of Urban and Rural Transport and the ‘OVpay Check-in/out Terms and Conditions using your Debit Card and Credit Card’ apply.
The provision of Cross Service (see C. Service/Cross Service) is based on the legitimate interests of the Public transport operators and Translink. The Public transport operators and Translink would like your questions to be answered as well and as efficiently as possible via just one service point rather than several. It is in your interests as a traveller, as well in the interests of the Public transport operators and Translink, that we can handle your questions about travelling with several Public transport operators properly and efficiently. Our service staff are only given access to the data they need to answer your questions.
Managing notifications for checking in and checking out in the OVpay app is based on your consent.
Who are the Processors? What Personal Data do we use?
Your Personal Data is Processed by: GVB and Translink. GVB, the other Public transport operators and Translink are Joint controllers for processing Personal Data relating to travel using your contactless Debit Card. The conditions are established in a mutual agreement between the Public transport operators and Translink. The joint controllership relates to the following processes and the associated Personal Data:
Process | Legal ground | Purpose | Personal data | Retention period |
|---|---|---|---|---|
Tapping | Performance of a contract | Status check Debit Card and validation of travel transaction | Technical Debit Card data (PAN, PAN serial number and validity date); Tap data | 24 hours maximum |
Processing taps (Transaction processing) | Performance of a contract | Processing of taps; | Technical Debit Card data (PAN, PAN serial number and validity date); pseudonymised tokens; Travel transaction data | 18 months |
Central traveller support (self-service) – without and with service account | Performance of a contract | Providing passengers with insight into travel and payment transactions and outstanding debt via OVpay website and Ovpay app; | Payment reference number; Payment transaction data; Outstanding debt; Travel transaction data.; pseudonymisation tokens; name, or name, date of birth and/ or photo. | Until service is provided; no data is left behind on the website or in the Ovpay app; |
Decentral traveller support (self-service) - with service account at Public transport operator | Performance of a contract | Providing passengers with insight via website/ app of Public transport operator into: | Payment reference number; outstanding debt; travel transaction data | Until service is provided; no data is left behind on the website/ in the app |
Decentralised traveller support via customer care - cross service | Legitimate interests of Public transport operators and Translink | Via Customer care (counter or telephone) of Public transport operator to inform about: | Payment reference number; Payment transaction data; Outstanding debt; Travel transaction data | Until service is provided, Public transport operator’s Customer care only has view on transaction data |
Inspection/checking of valid ticket | Performance of a contract | - Based on check-in/ check-out with Debit Card, checking whether a passenger has a valid electronic Ticket when using public transport (; and if applicable checking the validity of the discount product and/ or profile; | Technical Debit Card data (PAN, PAN serial number and validity date); pseudonymisation tokens; Travel transaction | Data will automatically be deleted as soon as the inspection device receives a reply that the Debit Card has been checked in/out and 5 minutes have passed, another Debit Card is presented for inspection, or the inspection (app) is closed. |
Mobile service to passengers | Consent | Upon request from a passenger, the inspector can scan the Debit Card to provide information on the last ten travel transactions made on public transport using the same Debit Card | Technical Debit Card data (PAN, PAN serial number and validity date); pseudonymisation tokens; Travel transaction data | Data will automatically be deleted as soon as the inspection device receives a reply that the Debit Card has been checked in/out and 5 minutes have passed, another Debit Card is presented for inspection, or the inspection (app) is closed. |
Composing and delivering of feedback reports regarding processing of travel transactions | Legitimate interest Translink; legitimate interest and legal obligation Public transport operators | Safeguard integrity of the public transport system (e.g. validating transactions) and administer contract of carriages, financially closing the loop of transactions as well as enabling financial administration and accountability | Travel transaction data (such as check-in/check-out; date/time; location; means of transport; journeys and prices per journey); pseudonymisation-tokens; | 18 months (legitimate interest); 7 years (legal obligation) |
With whom do we share your data?
GVB, the other Public transport operators and Translink, make use of the services of Processors. We always sign written agreements with external parties (such as IT suppliers) who process Personal Data on our behalf. We do this by entering into a so-called ‘processor’s agreement’, in which among other things we stipulate agreements about the security of your Personal Data and about the use of the Personal Data.
Translink engages the services of EMS for handling payments with your Bank. To process the payment, Translink provides the Technical Debit Card details and the Payment reference number to the financial institution. EMS Processes this data in its capacity as Controller.
In certain cases, the Public transport operators and Translink have the obligation bases on legal obligations to share your data with third parties.
Security of the Personal Data
GVB, the other Public transport operators and Translink will secure your Personal Data, for example against unauthorised access, loss and theft. GVB, the other Public transport operators and Translink all have policies in place for making public transport payments using the Debit Card in such a way that an appropriate level of security is applied by default.
Translink makes use of the services of iProov ( iProov Ltd, www.iproov.com) for taking your photo in the Ovpay app. This photo is required to apply for age discount as part of a discount profile for bus, tram and metro at urban and regional transport. iProov Processes this data as a Processor.
The Public transport operators and Translink apply PCI DSS for the security of Debit Card details. This is an international information security standard drawn up by Banks. The standard seeks to protect payment card details and prevent misuse of card information and, by extension, damage.
Your Technical Debit Card details will only be processed in card readers at GVB and in the central administration system of Translink in pseudonymised form.
Automated decision-making
Automated decisions are taken in two cases: when a fare is still owed, and when a Debit Card has been blocked by a Bank.
1. A fare that is still owed
As a passenger you always have to pay the fare that is due. If your Bank is unable to process your payment, the travel function of the Debit Card will automatically be blocked (temporarily). You can then still check out for a journey, but you cannot check in (again) for a journey.
If the travel function of the Debit Card is blocked due to insufficient balance, you cannot check in again with this Debit Card until your debt has been settled. For your Debit Card repeated attempts may be made to debit your account within a period of 62 calendar days.
You may object to this automated decision whereby your Debit Card is blocked (temporarily). The reason for blocking the Debit Card will be reviewed by OVpay Customer care, and the card will be unblocked if warranted.
2. Debit Card blocked by a Bank
If a Debit Card, which has been used in public transport, has been reported stolen or missing by a Bank, or if there is another reason why the card has been blocked (temporarily) by the Bank, the travel function of the Debit Card will also automatically be blocked (temporarily). For your Debit Card this is also part of the General Terms and Conditions for using your Debit Card that you have agreed with your Bank.
The Public transport operators and Translink cannot change this (temporary) block. If you have any questions about this, please contact your Bank.
Contact point for questions regarding, or exercising your privacy rights, when travelling with a contactless Debit Card or Credit Card
Contact point for questions regarding, or exercising your privacy rights, when travelling with a contactless Debit Card
Questions
If you have any questions about the Processing of your Personal Data relating to travel with a Debit Card, you can contact the existing contact points at GVB and Translink.
In principle, GVB and Translink can only answer specific questions or fulfil your rights by using the features of your Debit Card. If you have created an account in an App, if you have linked your Debit Card to this account and if you have provided Personal Data, GVB and Translink will be able to service you as well based on these data. Before getting insight in your travelling, you have to provide a Payment reference number and corresponding amount.
For general questions about travelling with a Debit Card, please contact the OVpay Customer care Desk by calling 0900-1433, or by completing the contact form at www.ovpay.nl/contact.
If you would like more information on how GVB or Translink handles your Personal Data, please contact the Data Protection Officer of either organisation:
For GVB:fg@gvb.nl, forTranslink:fg@translink.nl
Exercising privacy rights
If you wish to exercise your privacy rights, you can do so by contacting our Customer care or that of Translink, or by contacting the Data Protection Officer of GVB or Translink; see the contact details above.
