Privacy Notice

1. Who is responsible for your information?

The organisation responsible for personal information depends on why the information is being processed.

Schools and trusts

Schools and trusts using ViaNaro will normally be the data controller for information about their pupils, staff, drivers, trips and transport operations.

They decide why that information is required and how it should be used. ViaNaro processes that information on their behalf and in accordance with their instructions.

If your question concerns information held by your school or trust within ViaNaro, you should normally contact that organisation in the first instance. Its own privacy notices will also apply.

ViaNaro

Simon Bristow trading as ViaNaro is the data controller for limited information processed for ViaNaro's own purposes, including administering and securing the service, managing access to the platform, diagnosing technical problems and dealing with enquiries made directly to ViaNaro.

2. Information processed through ViaNaro

Depending on how your organisation uses ViaNaro, the service may process the following categories of information.

Account and identity information

This may include:

• name and email address;
• organisation, school or trust membership;
• user role and permissions;
• account and sign-in status;
• authentication and security information;
• information received from an organisation's identity provider, such as Microsoft Entra ID; and
• information required to operate security features such as passkeys or multi-factor authentication.

Passwords are not stored in readable form.

Where biometric authentication such as Face ID or fingerprint authentication is used on a device, ViaNaro does not receive or store the person's biometric template. The device performs the biometric check.

Staff and driver information

Where relevant to transport operations, information may include:

• driving entitlements and qualifications;
• vehicle preferences;
• driver availability;
• workload limits;
• information relevant to determining whether somebody is eligible or available to drive;
• operational notes; and
• information required to manage transport resources.

Pupil and passenger information

Pupil registers are an optional ViaNaro feature. Each school or trust decides whether to use them and what pupil information to enter.

ViaNaro does not require schools to use a pupil's full name. The school or trust determines how pupils are identified within its registers, taking account of its own operational and safeguarding requirements and the principle of using no more personal information than is necessary.

Where pupil registers are used, ViaNaro may process the identifier or name entered by the school, together with information such as whether the pupil was present, their return status (including where they were collected by a parent), the vehicle used and relevant operational comments.

The school or trust remains the controller of this information and determines what pupil information is entered into ViaNaro.

The current trial does not use ViaNaro's future home-to-school functionality for storing medical or safeguarding records. The privacy arrangements for that functionality will be reviewed and this notice updated before it is introduced.

Trip and booking information

This may include:

• trip names and descriptions;
• dates and times;
• passenger and staff numbers;
• named staff associated with a trip;
• origins and destinations;
• addresses and place information;
• route distances and estimated journey times;
• vehicle and driver allocations;
• journey and registration records;
• operational notes; and
• documents or evidence uploaded in connection with bookings, vehicles or inspections.

Location coordinates associated with places may be obtained from address and mapping services.

ViaNaro does not currently collect live location information from a user's mobile device.

Mobile app and technical information

The ViaNaro mobile app may process:

• an installation identifier;
• device platform and application version;
• push-notification tokens;
• information needed to maintain a secure signed-in session;
• limited network and synchronisation information; and
• diagnostic information where required to identify errors or protect the service.

The app may retain limited operational information on the device so that relevant trip information remains available when connectivity is poor. This information is cleared when the user logs out.

Voice features

Where a user chooses to use a ViaNaro voice or dictation feature, audio is transmitted for transcription.

Where transcription is enabled, audio may be processed by OpenAI to convert speech into text. ViaNaro does not retain the audio recording as an audio file after transcription.

The resulting text may be retained where the user chooses to save or submit it as part of a booking, request, note or other ViaNaro record.

Users should avoid dictating unnecessary personal or sensitive information.

3. Where information comes from

Personal information processed through ViaNaro may be provided by:

• the individual using ViaNaro;
• their school, trust or employer;
• authorised administrators or other members of staff;
• an organisation's identity provider, such as Microsoft Entra ID;
• approved integrations used by the organisation;
• mapping and routing services; and
• the user's device where necessary to provide mobile-app functionality.

4. Why information is used

Schools and trusts determine the purposes for which ViaNaro processes information on their behalf.

These purposes may include:

• planning and managing school transport;
• creating and administering trips;
• allocating vehicles and drivers;
• maintaining passenger and journey registers;
• managing transport resources;
• communicating assignments, reminders and operational changes;
• maintaining records relevant to transport operations; and
• supporting the safe and effective operation of school transport.

Where ViaNaro is itself the controller, personal information is used to:

• administer access to the ViaNaro service;
• authenticate users and protect accounts;
• maintain the security and integrity of the service;
• investigate and diagnose technical problems;
• prevent misuse or unauthorised access;
• support users and respond to enquiries; and
• operate, maintain and improve the reliability of the service.

5. Lawful basis

Where a school or trust is the data controller, that organisation is responsible for determining the appropriate lawful basis for its processing. ViaNaro processes the information on the controller's instructions.

Where Simon Bristow trading as ViaNaro is the controller, ViaNaro generally relies on legitimate interests where processing is necessary to administer, secure and support the ViaNaro service.

Those legitimate interests include:

• providing and administering a secure transport-management service;
• protecting ViaNaro, its users and customer organisations against unauthorised access and misuse;
• maintaining service reliability;
• investigating faults and security incidents; and
• responding to enquiries and providing support.

ViaNaro considers the necessity and proportionality of this processing and the rights and interests of the people concerned.

Where another lawful basis is required by law for a particular activity, that basis will be identified and applied.

6. Automated allocation and decision-making

ViaNaro can assist schools with allocating vehicles and drivers.

Depending on the school's settings, allocations may be made manually, generated as recommendations for a person to confirm, or generated automatically.

Allocation may take account of operational factors such as vehicle capacity, driving entitlement, availability, workload, journey requirements and estimated transport costs.

Authorised staff can review and change allocations, and where required a driver must accept an assignment before it is confirmed.

This functionality is intended to assist with operational transport scheduling. It is not used by ViaNaro to determine a person's legal rights, eligibility for education or admission to a school.

7. Organisations that help provide ViaNaro

ViaNaro uses specialist service providers to operate the platform. Depending on the features being used, these may include providers of:

• application hosting and database infrastructure;
• email delivery;
• mapping and routing;
• identity and authentication services;
• speech transcription and AI-assisted drafting;
• mobile-app infrastructure and notifications; and
• secure file or object storage.

Current technology providers may include Vercel, Microsoft, Google, OpenAI, Expo, Resend and Wonde, where the relevant service or integration is enabled.

These organisations process information only where necessary for the relevant service and are subject to their applicable contractual and data-protection arrangements.

ViaNaro does not sell personal information and does not use personal information for third-party advertising.

8. International transfers

Some of the technology providers used to operate ViaNaro may process information outside the United Kingdom.

Where personal information is subject to a restricted international transfer, ViaNaro will use an appropriate mechanism recognised under UK data-protection law, where required. This may include processing in a country covered by UK adequacy regulations or the use of appropriate contractual safeguards.

Further information about the safeguards applying to a particular service can be requested from privacy@vianaro.co.uk.

9. How long information is kept

ViaNaro does not retain personal information for longer than is necessary for the purpose for which it is processed.

Where ViaNaro processes information on behalf of a school or trust, retention and deletion are principally determined by that organisation's requirements and instructions.

The appropriate period depends on the nature of the information and why it is required. Relevant considerations include:

• whether an account, booking, trip or operational record remains active;
• the school's or trust's retention requirements;
• security and audit requirements;
• the need to investigate or resolve an incident or dispute; and
• applicable legal or regulatory requirements.

Information may therefore remain within historic transport records where the controller has a legitimate need to retain those records.

Authentication credentials, device tokens and temporary technical information are removed, revoked or expire when they are no longer required in accordance with the operation of the service.

Audio submitted for speech transcription is not retained by ViaNaro as an audio recording after transcription. Any resulting text is retained only where it forms part of a record that is saved within the service.

ViaNaro will continue to review and formalise its retention arrangements as the service develops.

10. Security

ViaNaro uses technical and organisational measures intended to protect personal information against unauthorised access, loss, alteration or disclosure.

These include measures such as:

• access controls and role-based permissions;
• secure authentication;
• multi-factor authentication options;
• encryption of appropriate credentials and secrets;
• secure communications;
• session and device controls;
• audit and security logging; and
• controls intended to prevent users accessing information belonging to organisations they are not authorised to access.

No online service can guarantee absolute security. Security concerns relating to ViaNaro can be reported to security@vianaro.co.uk.

11. Children's information

ViaNaro is a service for authorised staff and is not intended to be used directly by children.

Schools and trusts may nevertheless use ViaNaro to process limited personal information about pupils where this is necessary for their transport operations.

Pupil registers are optional, and the school or trust decides whether to use them and how pupils are identified. ViaNaro does not require a full pupil name where the controller considers a less identifying reference sufficient for its operational and safeguarding needs.

The school or trust remains responsible for determining why pupil information is processed and ensuring that its use is lawful, fair and appropriate.

ViaNaro recognises that children's information requires particular protection and seeks to limit the information processed to what is required for the relevant transport function.

12. Cookies and information stored on devices

The ViaNaro website uses cookies and similar storage necessary to:

• keep users securely signed in;
• maintain the appropriate organisation or school context; and
• remember functional display preferences.

ViaNaro does not currently use advertising cookies.

The mobile application uses secure device storage for authentication information and may retain operational data needed for app functionality and offline access.

13. Your data-protection rights

Depending on the circumstances and the lawful basis being used, data-protection law gives individuals rights over their personal information. These may include the right to:

• obtain information about how their personal information is used;
• request access to their personal information;
• have inaccurate information corrected;
• request deletion of information in certain circumstances;
• request restriction of processing in certain circumstances;
• object to certain processing, including processing based on legitimate interests; and
• receive certain information in a portable format where the right to data portability applies.

These rights are not absolute and may not apply in every situation.

For information processed by a school or trust as controller, requests should normally be made to that organisation. ViaNaro will assist the controller where required.

For information for which ViaNaro is the controller, requests can be made to privacy@vianaro.co.uk.

14. Complaints

If you have a concern about information controlled by a school or trust, you should normally raise it with that organisation first.

For concerns about information controlled by ViaNaro, please contact privacy@vianaro.co.uk so that the matter can be investigated.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data-protection regulator.

Information about making a complaint is available at ico.org.uk.

15. Changes to this notice

This notice reflects the current limited trial of ViaNaro.

It will be reviewed as the service develops and will be updated before material new processing is introduced.

In particular, the notice and associated data-protection arrangements will be reviewed before ViaNaro's home-to-school functionality involving additional categories of pupil information is introduced, and when the legal entity operating ViaNaro changes.

The date at the top of this notice will be updated whenever material changes are made.