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E-mail me when tickets become available Back to calendar1. Executive Summary
2. Privacy Policy
2.1. What personal data do we collect?
2.2. Cookies
2.3. How do we use your personal data and what is the legal basis for such processing?
2.4. Sharing Your Information
2.5. Data Retention
2.6. Information Security
2.7. Transferring Information Internationally
2.8. Updates to this Privacy Notice
2.9. Your Data Protection Rights
2.10. Questions about this Privacy Notice
CrossCountry (”We”) are committed to protecting and respecting your privacy.
This policy (together with our Website Terms of Use (www.crosscountrytrains.co.uk) and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website (either www.crosscountrytrains.co.uk or www.buytickets.crosscountrytrains.co.uk ) or providing your information in the circumstances described below, you are accepting and consenting to the practices described in this policy.
This policy was last updated 11/12/2018
For the purpose of Data Protection Legislation, the data controller is XC Trains Limited (known as CrossCountry), Admiral Way, Doxford International Business Park, Sunderland, SR3 3XP
2.1. What personal data do we collect?
Information provided by you.
You may give us information about you by filling in forms on our site www.crosscountrytrains.co.uk or www.buytickets.crosscountrytrains.co.uk or that you email to us by corresponding with us by phone, e-mail or otherwise. This includes when you subscribe and/or register for any service that we may provide via our site or when you complete transactions or respond to surveys. This also includes information you provide when you register to use our sites, download our app, subscribe to our services, purchase tickets, register to receive email updates, register with us to use our on-train WiFi service, enter a competition, promotion or survey, when you contact us via our social media channels and when you report a problem with our sites or make a complaint.
The information you give us may include:
Passive collection of information
We may collect and process anonymous information about your use of the Website or Booking Service, such as some of the pages you visit and some of the searches you perform. Such information is used by us to help us improve the contents of the Website or Booking Service and to compile, for internal market research purposes, aggregate statistics about individuals using it. This kind of anonymous information can be obtained by our use of "cookies" as well as other means. Please see Section 2.2, 'Cookies' for more information on our use of cookies. We may also share anonymous information about your use of the Booking Service with third parties for analytical purposes.
Information we collect about you.
With regard to each of your visits to our sites or when you register to use our on-train WiFi services we may automatically collect the following information:
Information we receive from other sources.
We may receive information from other sources if you have provided permission for this to happen or if there is a legal reason for it to occur.
We may receive information about you if you use our website. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
Sensitive personal data
We will not intentionally or systematically seek to collect, store or otherwise use information about you classed as ‘special categories of data' or 'sensitive data'.
If you require any extra assistance to help you make your journey, we offer our Passenger Assist service, this may involve you providing us with sensitive personal data.
Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our sites. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy at https://www.crosscountrytrains.co.uk/cookie-policy.
2.3. How do we use your personal data and what is the legal basis for such processing?
The collection of the personal data described above is usually mandatory and, if such personal data is not provided, we will not be able to provide the information, products and services to you. Where the collection of any personal data is not mandatory, we will inform you of this prior to collection, as well as the consequences of failing to provide the relevant personal data.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally process your personal information only:
2.3.1. Information provided by you. We use your personal information as follows:
Information provided by you for Safety purposes
Area | Purpose of processing | Legal basis for processing |
Accidents, Incidents, Assaults, or Dangerous Occurrences
|
To meet our statutory obligations for the reporting of accidents, incidents, assaults or dangerous occurrences. For the reporting and investigation of safety related events for the purpose of preventing, or reducing the risk of their recurrence. Sharing with other organisations with a direct responsibility for maintaining, or improving railway safety.
To share within Emergency Services, as required during emergency situations on board our services |
The processing of the personal information is necessary for compliance with a legal obligation set by Office of Rail and Road Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR)
Legitimate interest and duty of care |
Claims | To handle your claim in accordance with Claim Allocation and Handling Agreement (CAHA) for losses, property damage or personal injury |
Necessary for the performance of the contract. Licence obligations of the Office Rail and Road – Claim Allocation and Handling Agreement (CAHA) |
Information provided by you as a Customer or Stakeholder
Area |
Purpose of processing |
Legal basis for processing |
Transactional data |
Provided by you as part of a financial transaction, such as payment for tickets, refunds or compensation |
Performance of a contract and Legal obligations |
Sending marketing information to customers |
Collecting, updating and using contact details such as email address, SMS and postal address to inform you about promotions, news, ticket offers and destination ideas that may be of interest to you |
Consent provided by you |
Pre and post travel information |
Issuing pre and post travel information, including destination ideas and booking information |
Consent provided by you |
Tracking and improving the performance of website |
Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access (this is used to help track and improve the performance of our website) |
Legitimate interest |
Performance tracking for targeted advertising |
Information about your computer, including IP address, operating system and browser type for website performance and improvement. This allows us to track performance and serve relevant advertising likely to be of interest to you and does not identify you as an individual. |
Legitimate interest |
Information provided by customers to us |
Information you provide to us by filling in forms on our site or that you email us. This includes when you subscribe or register for any service that we may provide via our site or when you complete transactions |
Performance of contract |
Research and surveys |
As part of customer research and surveys |
Legitimate interest |
Common law or statutory obligations |
Complying with any common law or statutory obligations, such as in the prevention of fraud |
Legal obligations |
Service updates |
Providing customers with updates to train services and / or strike information |
Performance of contract |
Social media |
Handling customer social media enquiries |
Legitimate interest |
Marketing communications |
Personal information such as your name and contact details when you register for an account or sign-up for marketing communications |
Consent provided by you |
Data analysis |
Profiling and selection customers in order to send relevant, targeted communications and information and improve services |
Consent provided by you |
Interactions with our website and our app |
Website visits and online behaviour, including app usage |
Legitimate interest |
On board WiFi data connection |
To provide you with a WiFi service on board our services |
Performance of a contract |
Trainline Customer contact centre |
To support in any queries with bookings, travel assistance or other issues. |
Performance of a contract |
Email analysis |
Email engagement statistics |
Consent provided by you |
Smart ticketing
|
Administration of your tickets and handling queries relating to your tickets. |
Performance of a contract and Legitimate interests. |
Customer research panel |
Joining our customer Research Panel |
Consent provided by you |
Social media |
Your messages to us via social media channels |
Legitimate interest |
Prize draw/giveaways/competition forms. |
To publish the name, county and winner of a prize draw or competition and if relevant, the winning entry in accordance with the requirements of the CAP Code. |
Legitimate interest to ensure compliance with the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code). |
Catering purchases on board |
To receive electronic receipts for Catering purchase made on board the train |
Consent provided by you |
Stakeholders - keeping you informed |
To provide you with information about our goods and services that may interest you or them |
Consent provided by you |
Stakeholders - supporting Rail Partnerships |
To support Community Rail Partnerships |
Consent provided by you |
Stakeholders - supporting community causes |
To support causes within the community |
Consent provided by you |
Information provided by you in relation to the provision of Customer Services
Area |
Purpose of processing |
Legal basis for processing |
Travel Assistance - Passenger Assist |
To arrange and carry out extra assistance for your journey |
Equality Act 2010, working with other Rail Industry partners to ensure compliance where complimentary services are supplied under contract. Please see our Accessible Travel Policy. |
Compliments, Suggestions, Complaints, reporting accidents and Appeals |
To respond, investigate and make the necessary enquiries regarding your initial correspondence. To respond, investigate and make the necessary enquiries regarding the appeal. To record and pass on details of accidents or injuries that have happened on our services to our Safety Team. |
Performance of a contract. Processing is necessary to protect the vital Interests
Legal Obligation |
Claims for Compensation and Refunds |
To provide compensation in line with our Delay Repay Scheme To handle the claims for compensation and refunds. |
To provide compensation in line with our Passenger Charter and National Rail Conditions of Travel |
Revenue Protection & Prosecutions Policy |
Preventing and reducing fare evasion and offenses of violence against its workforce, which may involve prosecution of perpetrators. |
For fare evasion - National Conditions of Travel and National Railway Byelaws (2005) Regulations of Railways Act 1889, For serious and systematic fare evasion or revenue fraud - Fraud Act 2006 For Assault against our employees is an offence - Criminal Justice Act 1988, Offences against the Person Act 1861 , Public Order Act 1986. Please see our Prosecutions Policy |
Information provided by you to our Human Resources Department
Area |
Purpose of processing |
Legal basis for processing |
Recruitment |
For pre-appointment assessment for either job vacancies, apprenticeships, placements or our graduate training program. To receive relevant notifications in regards to job vacancies with CrossCountry or other vacancies within the DB and Arriva organisations |
Necessary for the performance of a contract with you or to take steps to enter into a contract.
Consent provided by you
|
Information provided by you in relation to Subject Access Requests
Area |
Purpose of processing |
Legal basis for processing |
Subject Access Request |
To process and investigate any complaint, subject access request and other general requests under the General Data Protection Regulation. |
Consent provided by you. Legal obligation to process your personal information – General Data Protection Regulation (GDPR) |
Information provided by you in relation to you visiting a CrossCountry location
Area |
Purpose of processing |
Legal basis for processing |
Visitors |
To enable visitors to gain entry/access into CrossCountry location |
Legitimate interest |
2.3.2. Information we collect about you.
2.3.2.1We use your personal information as follows:
Information we collect about you for Safety purposes
Area |
Purpose of processing |
Legal basis for processing |
CCTV Cameras and Body Worn Cameras |
Images are recorded for the purpose of Customer, Security, Staff Security, Crime Prevention and Public safety on train, at stations, on platforms or at office accommodation. |
Necessary for the Legitimate interest, public interest task and/or legal obligation (prevention and detection of crime). |
Information we collect about you as Customer or Stakeholder
Area |
Purpose of processing |
Legal basis for processing |
Purchase of tickets |
Transactional information (such as your payment details when you buy tickets, the purchase and usage of WiFi) |
Performance of contract, legal requirement in relation to |
Marketing communications |
Personal information such as your name and contact details when you register for an account or sign-up for marketing communications |
Consent provided by you. |
Targeted communications |
Profiling and selection customers in order to send relevant, targeted communications and information and improve services. |
Consent provided by you |
Trainline Customer contact centre |
To assist customers with any queries in regards to their bookings, passenger assist requests and other issues. |
Performance of a contract |
Smart ticketing |
Administration of your tickets and handling queries relating to your tickets. |
Performance of a contract and Legitimate interests. |
Behaviour |
Website visits and online behaviour, including app usage |
Legitimate interest |
Engagement |
Email engagement statistics |
Consent provided by you |
Customer research panel |
Feedback via our Customer Research Panel (All submissions are made anonymous for analysis and reporting) |
Legitimate interest |
Prize draw/giveaways/competition forms. |
To publish the name, county and winner of a prize draw or competition and if relevant, the winning entry in accordance with the requirements of the CAP Code. |
Legitimate interest to ensure compliance with the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code). |
Social media |
Your messages to us via social media channels |
Legitimate interest |
Competitions |
Competition entry winners |
Consent provided by you |
Customer experience |
To gauge the experience and use feedback for service improvements such as Surveys |
Consent provided by you |
Customer Relations Call recording
|
To record calls for monitoring and training purposes. Potentially used as evidence in fraudulent cases (Note this does not include payment details) |
Performance of a contract and legitimate interest |
Information we collect about you as a potential employee:
Area | Purpose of processing | Legal basis for processing |
Recruitment | To send you relevant job vacancy updates | Consent provided by you |
2.3.3 Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Questions about this Privacy Notice” heading below.
Information we receive from other sources for Safety purposes
Area |
Purpose of processing |
Legal basis for processing |
Accidents, Incidents, Assaults, or Dangerous Occurrences
|
To meet our statutory obligations for the reporting of accidents, incidents, assaults or dangerous occurrences |
The processing of the personal information is necessary for compliance with a legal obligation set by Office of Rail and Road Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR) |
CCTV Camera and Body Worn Cameras |
Images are required for evidential purposes in legal or disciplinary proceedings |
Necessary for the Legitimate interest, public interest task and/or legal obligation (prevention and detection of crime). |
Safety Claims |
To handle your claim in accordance with Claim Allocation and Handling Agreement (CAHA) for losses, property damage or personal injury |
Necessary for the performance of the contract. Licence obligations of the Office Rail and Road – Claim Allocation and Handling Agreement (CAHA) |
Information we receive from other sources as a Customer
Area |
Purpose of processing |
Legal basis for processing |
Smart ticketing
|
Administration of your tickets and handling queries relating to your tickets, which may contain other Train Operating Companies’ products |
Performance of a contract and Legitimate interests. |
Guest Checkout |
You can use our booking service without registering as a new user on our mobile site, website or through our app. Transactions as a guest would however not be displayed in your account if you are a registered user, but subsequently choose to checkout as a Guest. All personal data collected when booking as a Guest will be processed in accordance with this Privacy Policy. |
Performance of a contract |
Information we receive from other sources for the provision of Customer Services
Area |
Purpose of processing |
Legal basis for processing |
Travel Assistance |
To carry out assistance for your journey |
Peformance of a contract |
Compliments, Suggestions, Complaints and Appeals |
To respond, investigate and make the necessary enquiries regarding your initial correspondence. To respond, investigate and make the necessary enquiries regarding the appeal. |
Performance of a contract Processing is necessary to protect the vital interests |
Claims for compensation and refunds |
To assist with the Customer Delay repay claim by sharing the information with the appropriate Other Train Operators. |
To provide compensation in line with our Passenger Charter and National Rail Conditions of Travel |
Revenue Protection & Prosecutions |
To support revenue protection related investigations that may lead to prosecutions. |
National Conditions of Travel and National Railway Byelaws |
Information we receive from other sources in our Human Resources Department
Area |
Purpose of processing |
Legal basis for processing |
Recruitment |
We may receive references from previous employers. We may also receive reports from external suppliers for pre-employment testing or medicals reports |
Necessary for the performance of a contract with you or to take steps to enter into a contract. |
Information we receive from other sources in relation to Subject Access Request
Area |
Purpose of processing |
Legal basis for processing |
Subject Access Request |
Processing and investigating of Data Protection complaints received from the Information Commissioner’s Office |
Consent provided by you. Legal obligation to process your personal information – General Data Protection Regulation (GDPR) |
We may disclose your personal data to the following categories of recipient for the purposes described in this Privacy Notice:
Sharing your information for Safety Purposes
Sharing your information as Passenger/Member of the Public or Stakeholder
Service providers:
Other UK Rail Operators:
The Authorities:
Sharing your information for the provision of Customer Services
Sharing your information – Human Resources Department
Sharing your information in relation to Individual Rights Requests
Other
Finally, we may disclose your data to any other person to whom you request us to make disclosure or if you consent to such disclosure.
We will not retain your personal data for longer than is necessary to fulfil the purposes for which we collected that personal information, unless the law permits or requires that we retain it for longer.
The table below explains in more detail how long CrossCountry will store different types of information for:
Data Retention - Safety purposes
Customer information |
Retention Period |
Reporting of accidents, incidents, assaults or dangerous occurrences |
As per the Statutory provisions (see Social Security (claims and payments) Regulations 1971; Regulation 25. Social Security Act 1992; OR Section 8. Limitation Act 1980. |
Records relating to accident/injury |
From the date of the incident plus 12 years. In the case of serious accidents, a further retention period may need to be considered. |
CCTV Cameras and Body Worn Cameras |
Maximum 30 days dependant of system capabilities from record creation, unless there is a specific request relating to the CCTV/camera footage. Where there is a specific request which includes crime. Terrorism and HM Coroner relating to the CCTV/camera footage, the footage will be kept for the duration of the claim matter, plus an additional six years after the claim is closed. |
Safety claims |
For the duration of the claim, plus an additional 6 years after the claim is closed. |
CCTV footage relating to a claim
|
For the duration of the claim matter, plus additional 6 years after the claim is closed. |
Claimant bank details |
Until payment is made to the claimant |
Data Retention relating to the provision of Customer or Stakeholder
Customer information |
Retention Period |
For customers who have made an online transaction in the last 6 years |
Transaction history |
Anonymised website data |
We will keep anonymised website data (including but not limited to traffic data, location data, operating systems and browsing information) for 38 months. This data helps us with the ongoing improvement and development of our website and does not identify users individually (for example through a MAC address, IP address or cookie data). |
Stakeholder – General |
For no longer than the necessary for the purposes for which the personal data was collected. |
Stakeholder – Community Rail |
For no longer than the necessary for the purposes for which the personal data was collected. |
Stakeholder – Supporting causes in the community |
For a period of 6 years after the support is provided. |
Trainline contact centre call recording |
3 months |
Call recording (Customer Relations) |
2 years from point recording was made. Please note payment details are not recorded. |
Data Retention relating to the provision of Customer Services
Customer information |
Retention Period |
Travel Assistance bookings |
For a period of 2 years (as advised by Rail Delivery Group) |
Compliments, Suggestions, Complaints and Appeals |
For no longer than the necessary purposes for which the personal data was collected (maximum period of 6 years) |
Compensation & Refunds |
6 years from the date of transaction or payment made |
Revenue Protection & Prosecutions Policy |
For a period of 6 years following the end case completion |
Data Retention – Human Resources Department
Customer information |
Retention Period |
Job applications and interview records for unsuccessful candidates |
6 months after notifying unsuccessful candidates. The applicant should be informed of Arriva’s retention period when they complete the application |
Data Retention - Individual Rights Access
Customer information |
Retention Period |
Individual Rights Requests |
We hold the data for 2 years |
We apply appropriate administrative, technical and organisational security measures to protect your personal data that is under our control from unauthorised access, collection, use, disclosure, copying, modification or disposal. All information you provide to us is stored on secure servers. We are part of the Arriva plc Group, which trains its employees regarding our data privacy policies and procedures and permit authorised employees to access personal data on a need to know basis, as required for their role. We also take steps to ensure that any service provider that we engage to process personal data on our behalf takes appropriate technical and organisational measures to safeguard such personal data.
2.7. Transferring Information Internationally
Your personal information may be transferred to and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. Specifically, we may use third party service providers located in India, Tunisia and the United States of America. This means that, when we collect your personal information, it may be processed in these countries. However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Notice. These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information to our third party service providers and further details can be provided upon request.
2.8. Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the date displayed at the top of this Privacy Notice.
2.9. Your Data Protection Rights
You have the following data protection rights:
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You can update your consent preferences in our Preferences centre, please note that it may take up to 48 hours for this information to be updated.
If you wish to withdraw consent from marketing communications, or close your online account with CrossCountry, please contact us at any time at digital@crosscountrytrains.co.uk Please note this may take up to 5 working days.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
2.10. Questions about this Privacy Notice
If you have any question, concerns or complaints about this Privacy notice or our handling of your personal data, you can contact us by email on XCDataProtection@crosscountrytrains.co.uk or by post to the following address:
CrossCountry Data Protection Champion, CrossCountry, 5th Floor, Cannon House,18 The Priory Queensway, Birmingham, B4 6BS
If you are unsatisfied with the response, you can contact Arriva plc's Data Protection Officer at data.protection@arriva.co.uk.
You have the right to complain to a data protection authority about our collection and use of your personal information. If you are based in the European Economic Area, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries are available on the EU Commission's website via the following link): https://ec.europa.eu/info/departments/justice-and-consumers_en#contact).