If you use an Oyster card for travel please see our Oyster privacy page.
Contactless payment methods can include bank/credit cards, mobile phone applications, key fobs, wristbands, payment stickers and tags. Please see What is a contactless payment card to find out more.
Personal information we hold
Some of the data listed below is only held if you have registered your payment card, for example by adding it to an online account. See the Obtaining and using your personal data section for more detail:
- Title, name, billing address, email address, telephone number (including mobile phone number)
- Customer ID
- Password/memorable information/telephone pin number
- The PAN (16 digit number) and expiry date of each contactless payment card registered
- Mobile device number (unique code used to identify a device where a customer has opted in to receiving notifications via the TfL Oyster and contactless app)
- Journey history (including journeys made on National Rail services that accept contactless payments)
- Your marketing and contact preferences
- Transaction information (including journeys and refunds)
- Enquiries, complaints or other correspondence from you
If we ask for the three digit CVV or CSV code from the reverse of your card (or the four digits on the front for AMEX cards), this is for validation/verification purposes only, for example it helps us to check with your card issuer the card has not been reported lost or stolen.
If you sign in to your online web account, we will collect the IP address used by your device for the purpose of fraud prevention and detection.
Legal basis for using your information
Under privacy and data protection legislation, we may only use personal information if we have a proper reason or 'legal basis' to do so. In the case of contactless, there are a number of these 'legal grounds' we rely on, which are:
- Our statutory and public functions:
- to undertake activities to promote and encourage safe, integrated, efficient and economic transport facilities and services, and to deliver the Mayor's Transport Strategy
- Where you have given us your consent, for example:
- where you have opted in to receive marketing messages or in-app notifications from us; or
- you have asked our contact centre to resolve an issue or complaint for you
- For the 'performance of a contract', for example:
- in connection with paying for a journey
- where you have created an online account so we can provide additional services to you
- For the 'purposes of legitimate interests':
- to enable train operators to plan and improve services. Train operators are companies providing National Rail services which accept the use of Oyster and contactless payment cards on their services
- to verify your identity when you contact us or log on to your account
- to process data for online account security monitoring purposes
Obtaining and using your personal information
Using your online account
The personal data we hold is provided by you when you create an online account via our website or app and register your contactless payment card, or use a contactless payment card on the TfL network, and on other services on which Contactless payment cards are accepted. Depending on how you set up an account and attach a contactless payment card to it, we will request only necessary information from you. For example, if you create an account via the app we do not require a security question and answer, or telephone pin number. If you set up the account via our website, or access your app account via our website, this additional information is required.
When you contact TfL
If you contact Customer Services, we will need to collect information from you so that we can respond to your query or request. If you phone us we may record your call so we can train staff, review call quality and have access to a verbal record of what has been said in the event of a subsequent complaint. At the end of your contact with us, we may email you to take part in a customer satisfaction survey about your experience with Customer Services. This helps us monitor our performance, improve quality and plan for future services.
We sometimes also undertake analysis or research into the types of subjects that commonly cause customer concerns and complaints. For example we might look for key words or themes and this helps us improve and plan our services for the future. Pseudonymisation, or other appropriate data minimisation techniques are applied so that we can analyse the subject matter without needing to know the identity of the person themselves. This is a way of protecting people's privacy in line with the Information Commissioner's Anonymisation Code of Practice.
Contacting you by email
If you sign up for an online account via our website or app and provide your email address, from time to time we will send you travel related information by email. These service messages contain useful information in relation to the way you travel, and might include:
- important changes to services you use
- new travel services
- travel disruption
- information about fares
- consultations on TfL's plans for transport in London
- changes to terms and conditions of travel
We appreciate that you don't always want to be contacted in this way, so all our emails will include a hyperlink so you can opt out from receiving future service messages at any time.
We will only send you messages about TfL's offers and promotions (marketing messages) if you choose to receive them, and you can change your marketing preferences at any time.
On occasion we may also send you details of surveys for you to participate in. Some of these surveys are based on your use of TfL services (e.g. journey information, services used, frequency of use, etc). These emails will also include a hyperlink so you can opt out of future surveys.
There are some communications that we have to send you to fulfil our contractual obligations to you. These include emails regarding some financial transactions (such as processing a refund) and important account updates where you have created an online account or downloaded the app.
We will never pass your personal information to any other organisation for marketing purposes without your prior consent.
Information about the journeys you take
Our ticketing systems record the location, date and time a contactless card is used to make a journey on TfL's network, affiliated National Rail services or London River services.
Using journey information to plan and improve services
Understanding how our customers use the transport network allows TfL and Train Operating Companies to plan, manage and improve services. The information used for these purposes doesn't contain customers' personal data. Each payment card is given a unique reference number that isn't linked to the individual, the 16 digit card number, the CVV code or the expiry date. We do not combine this data with CCTV or other sources of data that could identify individuals. This type of data is called pseudonymised journey information, and it allows organisations to carry out transport research without identifying individuals.
We use pseudonymised journey information to carry out research and analysis, for example, to look at travel demand, provide customers with information on how busy stations are at particular times and to make improvements to our transport services. This helps us meet our responsibilities under the Greater London Authority Act 1999; including the delivery of the Mayor's Transport Strategy and the promotion and encouragement of safe, integrated, efficient and economic transport facilities and services to, from and within Greater London. From time to time we may use this information in connection with our other statutory rights and obligations.
We use pseudonymised journey information to undertake intelligence, analysis and research activities to identify and inform responses to a number of safety issues including:
- Reducing all crime and anti-social behaviour on and around the public transport network
- Creating crime and anti-social behaviour strategies
- Targeting crime and disruption hotspots to better coordinate and deploy policing resources
- Reducing fear of crime and improving public confidence in the safety of the journeys they make in the capital
Pseudonymised information about journeys made using Pay as You Go that have been taken entirely or partly on routes served by National Rail services is provided to National Rail train operating companies for the following purposes:
- To set prices with TfL;
- To predict future income, set fares and allocate revenue between train operating companies;
- To better understand passenger demand for business, leisure and commuting journeys, and predict how this may change in the future;
- To understand the scope and extent of flexible travel to inform initiatives to encourage passengers to travel outside of peak periods;
- To assess the benefits of proposed investments in infrastructure and to inform strategic long-term railway planning;
- To allow other train operating companies to bid to provide services
Pseudonymised information is processed on the basis of legitimate interests of Train Operating Companies and for the performance of a task carried out in the public interest, or the exercise of TfL's official authority. You have the right to object to use of personal data that is processed on this basis. See the Your information rights section for more detail.
Securing your online account
In 2023 we introduced multi-factor authentication (MFA) to strengthen the existing security measures for online accounts. Existing account holders are prompted to set up MFA when they sign in and for new account holders this is completed as part of the registration process. We request a mobile phone number which will be used each time you sign in to receive a text with a unique code to enter in the sign in screen. The phone number provided for MFA will only be used for the purposes of MFA, unless you have previously provided the number to TfL for a separate purpose (e.g. when liaising with Customer Services).
Choosing not to provide personal information
You can use your contactless payment card to travel at any time without providing any other personal information to TfL or creating an online account.
If you use contactless payment for travel in this way, we will still hold and use the payment card details and journey information in the ways described on this page; however, no other personal information (e.g. your name or address) will be linked to your transaction.
If you choose not to provide personal information to us, you will not be able to open an online account. It may also delay or prevent us from offering other services to you such as the resolution of complaints or concerns, or issuing you a refund.
See the Your information rights section for information about your rights, including accessing your information, raising an objection to the way it is used or requesting its deletion.
Length of time we keep information
We will retain personal information in line with our information disposal policies. This means that we will not hold information for longer than is necessary for the purposes we obtained it for.
We retain information about the individual journeys made using contactless payment for 13 months after the card is used. This is the case whether or not you have added the card to an online account. After this time, the journey information in the ticketing system is disassociated from your payment card number (ie pseudonymised). This 13 month period is necessary because the details of your journey and payment cannot be separated and, like other retailers, we have to retain this transaction data in accordance with financial service industry regulations.
In certain limited cases, some information about individual journeys will be held for a longer period of time. An example of this is where we hold data as evidence in relation to TfL's revenue protection function (including the issue of penalty fares and prosecutions for fare evasion).
You have the option to disassociate a contactless payment card from your online account at any time. If you ask us to do this, details of the card will also be disassociated from your other personal information.
Call recordings made when you contact Customer Services are kept for 6 months.
Keeping personal information secure
We take the privacy of our customers very seriously, and a range of robust policies, processes and technical measures are in place to control and safeguard access to, and use of, personal information associated with contactless payment cards.
This includes ensuring that your payment card data is handled in accordance with the Payment Card Industry Data Security Standard ('PCI DSS').
Anyone with access to personal information held in TfL's systems is required to complete TfL's privacy and data protection training on an annual basis.
In 2023 we introduced multi-factor authentication (MFA) to strengthen the existing security measures for online accounts - whether accessed via our website or app. MFA is an additional layer of security to the account sign in process, helping to confirm you are who you say you are each time you sign into your account. You may be prompted with a subsequent MFA request in certain circumstances.
Alongside account holders being prompted to complete an MFA request, account sign-ins are subjected to automated fraud and security monitoring to identify suspicious activity and further protect accounts and the information within them. This includes monitoring login activity at the point of sign in and over time (e.g. IP address, browser, geographic location determined by IP address, identity information, known compromised credentials, previous login behaviour, etc).
We also publish guidance on the steps you can also take to protect your personal information.
Automated processing and profiling
Under data protection legislation we have to let you know when we use your personal information to make an automated decision (without human intervention) that significantly affects you.
We calculate the fares you are charged using automated means - i.e. using the location where you start your journey (touch in) and, if travelling by train or tube, end your journey (touch out). If you use a pink card reader, that data will be used to confirm you took a particular route and charge you accordingly.
On some occasions, we may 'auto complete' a journey for you if you do not tap your payment card on a yellow reader at both ends of your journey. We do this based on other journeys you have made to estimate the likely origin or destination of the incomplete journey.
If you are due a refund as a result of us auto completing your journey (e.g. if you were originally charged a maximum single fare), we will also automatically load the refund amount to your payment card.
We may also automatically issue you a refund if your journey history indicates that you have been affected by a major disruption or an incident that has severely impacted your travel.
If you believe you have been incorrectly charged, or not received a refund you were due, you can ask our Customer Service team to review those transactions.
If you request a refund via your online account, to speed up the process we may assess this first via automated means. If this results in a decision not to issue a refund, you will be advised how to contact Customer Services.
We analyse journey patterns and transaction history to inform measures to protect against fare evasion and fraudulent transactions. We use this data in different ways. For example, to identify 'hotspots' so we can deploy Revenue Inspectors in certain London Underground stations or on particular bus routes.
We may also use the outcome of our analysis to contact customers directly, with advice to touch in and out at the correct stages of a journey. In cases where we suspect fraud, we might invite you to attend a formal interview with us.
We also use your journey history, travel patterns or frequently used stations as the basis for sending service and marketing messages. For example if you regularly use the Central Line, we might use this information to help decide that messages about service alterations on that line would be helpful for you to know. We may also use this information to send you relevant surveys from time to time.
Similarly, if you have provided us with your address, we may use postcode information to decide that it would be useful for you to know the about changes to travel services near where you live, such as a station or bus stop closure or a road closure or diversions.
The purpose of this type of profiling is to make sure that we send only information to people who will actually find it relevant and useful. You are able to opt out from receiving these kinds of messages at any time.
We have a statutory duty to do all we reasonably can to reduce crime and disorder on and around the transport system - and we work together with our local authority, policing, and other law enforcement partners as part of this. Journey patterns may also be used to inform police deployments to prevent and deter crime on the transport network. We use automated systems to prevent and detect fraud and protect the safety and security of our online services.
If you have an online account we will use automated processes to support the protection of the account - such as presenting MFA requests each time you sign in and subsequently once signed in in certain circumstances, and to implement fraud and security monitoring to identify suspicious activity at the point of sign in and over time. The purpose of this type of profiling is to further protect accounts and the information within them.
If you have any difficulties accessing your account you can contact Customer Services for support.
Sharing personal information
We have contracts with a number of service providers, who provide the majority of the administration and 'back office' services that ensure the efficient day-to-day operation of our electronic ticketing systems. This includes our electronic ticketing systems, some customer services support and the customer relationship database.
If you use your contactless payment card on National Rail services or river services, we may share your personal information with the companies operating these services for the same purposes as TfL handles your data, i.e. customer services and administration, the provision of travel related information, customer research and fraud prevention. Information about sharing pseudonymised journey data is provided in the Obtaining and using your personal information section of this webpage.
Where you have agreed to receive marketing messages from train operating companies, we will pass them your contact details.
We will not share the details of individual journeys with your bank or credit card provider. These transactions will appear on your bank or credit card statement in the same way as any other purchase made using that card.
From time to time, TfL or other organisations (such as your bank or credit card provider) may want to offer you the opportunity to participate in offers, promotions or fundraising initiatives linked to the use of contactless payment on TfL services. If this involves sharing information such as the details or cost of a journey you've made, we (or that other organisation) will always let you know and where appropriate seek your prior consent.
We have partnerships with a number of academic institutions in the UK, who work with us to analyse journey patterns and undertake travel modelling to help us understand the way our customers travel so we can improve and plan our services for the future.
Pseudonymisation, or other appropriate data minimisation techniques are applied and all academic research using this information is carried out in accordance with privacy and data protection legislation and protected by robust confidentiality agreements.
In some circumstances, disclosures of personal information to the police (and other law enforcement agencies) are permitted by data protection legislation, if they relate to the prevention or detection of crime and/or the apprehension or prosecution of offenders. Before any such disclosure takes place, the police are required to demonstrate that the personal data concerned will assist them in this respect. Each police request to TfL is dealt with on a strictly case-by-case basis to ensure that any such disclosure is lawful and in accordance with the data protection legislation.
We may also receive or disclose personal information about customers in relation to certain emergency situations or other incidents that require an immediate response. Such events may include those involving public health, public safety or national security matters, when access to personal information is necessary to manage the incident. In some situations, we may also be required by law to disclose your personal information to the police or other enforcement, regulatory or Government body, upon a valid request to do so. These requests will be assessed on a case-by-case basis and take into account privacy considerations before a disclosure is made.
TfL, its service providers and academic research partners currently process personal information relating to contactless payment within the UK and the European Economic Area. Any such processing is subject to appropriate contractual safeguards and carried out in accordance with the requirements of UK and EU privacy legislation.
Using the TfL Oyster and contactless app
If you download and use our mobile TfL Oyster and contactless app, certain information may be collected automatically. This may include the type of mobile device you are using and its unique identifier (such as the device name or ID), Internet Protocol (IP) address, Media Access Control (MAC) address, and IMEI number.
We also use analytics (similar to cookies on websites) which are small files that capture data to help us improve the app's performance. We use them to collect information about your use of the app, such as what app content you access most frequently, or if you receive an error message when using the app.
If you opt in, we will also send you notifications via the app. You can change your mind at any time by amending the settings within your device.
Find out more in the TfL Oyster and contactless app Terms and Conditions.
Your information rights
If you are a registered customer, you can see your journey history (for up to the last 13 months) and other transactions by signing into your TfL online account. You can also view and update the contact information we hold about you; as well as your contact preferences.
Unregistered contactless payment customers without an account can access the last seven days' journey history online. You will be required to enter your contactless payment card number, expiry date, card security code and billing address on each occasion you wish to access the last seven days of journey and charging data. We will use the information you provide to carry out an authorisation check with your card issuer and will not use or retain it for any other purpose.
You can also request a copy of your journey history by calling Customer services. You will be required to verify your card information and identity each time you access this service.
For access to other personal information we hold about you, please see our Access your data page on how to do this.
If you would like to unsubscribe from service or marketing messages, please use the link we include at the end of every email. You can also update your contact preferences within your online account - or by emailing email@example.com at any time.
You also have a number of other information rights which include:
- The right to question any information we have about you that you think is wrong or incomplete
- The right to object to how we use your data or to ask us to delete or restrict how we use it
- In some cases, the right to receive a copy of your information in a format that you can easily re-use
- The right to complain to the regulator - the Information Commissioner's Office
Our Privacy and Data Protection team considers and coordinate responses to requests and complaints from people whose personal information is processed by TfL and its subsidiary companies. You can contact the Data Protection Officer by email at firstname.lastname@example.org.
Changes to this page
It's likely that we'll need to update this statement from time to time, so check back here regularly to find out more. This page was last updated in May and July 2023 with details added relating to the introduction of multi-factor authentication, use of pseudonymised data and some additional required amendments.