Privacy notice

What the Club Card scheme collects, why, and how long it is kept.

Draft — to be reviewed by the Gibraltar Bus Company before launch.

Who is responsible

The Gibraltar Bus Company Limited is the data controller for Club Card applications and cards. Cycle It Ltd operates this application service and processes card payments on GBC's behalf.

What we collect

From your application: name, address, date of birth, nationality, place of birth, school or college, telephone number and email address. For a Junior card, the parent or guardian's name and email.
Your proof of eligibility: the document you upload.
A photograph of the cardholder, taken with the camera on your device or chosen from it.
Once a card is issued: the card number, issue and expiry dates, and a record of each time a driver checks the card.
If you pay a fee: the payment reference. Card details are entered on Revolut's own form and are never seen or stored by this service.

If you choose to scan a Gibraltar Identity Card to fill the form in, the two photographs are sent to Anthropic's Claude API to be read, and the fields it reads are shown to you to check before anything is submitted. Nothing read this way is treated as verified — a reviewing officer still looks at the images. The photographs are your proof of eligibility and are deleted with it as soon as a decision is made. You can always skip the scan and type the details in yourself.

Why

To decide whether you qualify for the concession, to issue and manage your card, to let drivers check that a card presented for travel is valid, and to keep the records GBC needs to run and audit the scheme.

The photograph has one purpose: it is shown to the driver when your card is scanned, so they can see that the card belongs to the person presenting it. It is not printed, not published, not used to identify you anywhere else, and not run through face recognition of any kind — a person looks at it and decides.

How long we keep it

Your proof document is deleted as soon as a decision is made — whether that decision is to approve or to reject. It is not kept for the life of the card. A nightly sweep re-checks this and deletes anything an interrupted request left behind. Documents on applications nobody ever decided are deleted after 90 days.
Your photograph lives as long as your card does, because that is what it is for. When a card expires, is withdrawn, or is replaced by a renewal, the photograph on it is deleted. If your application is rejected the photograph is deleted with the proof document, since no card will exist.
The application record and the card record are kept while the card is valid and afterwards as GBC's record of a concession granted. Driver check records are kept as the audit of card use.

Who sees it

Reviewing officers at the Gibraltar Bus Company, who see the application, the proof document and the photograph. Drivers, who when they scan a valid card see the photograph, the holder's name, the card type, the card number and the expiry date — never the application behind it, and never the proof document. The photograph is not shown for a card that is expired or withdrawn.

Enquiries about you

By applying for a Cross-Frontier Workers Card you agree that GBC may, in its absolute discretion, seek information relevant to your application from other entities such as the Police, employers and other authorities. This is GBC's long-standing condition for that card and is carried over from their paper application form.

Children

A Junior card application must be made by a parent or guardian, who consents to it and to GBC holding the child's information. All correspondence goes to the parent or guardian.

Your rights

You can ask GBC for a copy of what is held about you, ask for it to be corrected, or ask for it to be deleted. The Gibraltar Bus Company Limited, 75 Queensway, Gibraltar.

This page is available in several languages. The English version is the authoritative one: if a translation differs from it, the English text governs.