What organisations are law enforcement officials and other public authorities?

When Freenow refers to an "authority" in this guidance, this means any governmental, quasi-governmental organisation or any statutory body or duly authorised organisation with the power to enforce laws. Usually these are: public bodies of law enforcement, transportation watchdogs, tax overseeing bodies or any other public body authorised by law to request user data from Freenow. This usually does not include: Drivers, Passengers, Insurances, Banks, Lawyers, or other private commercial organisations.

Is it sufficient if I just send an e-mail for my request?

No - When requesting information from Freenow several requirements need to be met in order for Freenow to be able to provide the information. It is mandatory that we receive a written request, including the stampof the authority and the signature of the requesting official or an official electronically signed document. If you send an authority request exclusively per e-mail Freenow will not process your request.

Can I simply request all of the data stored for a user?

Usually not - Freenow is obliged to comply with relevant data protection laws, even when disclosing user data to authorities, and this means that Freenow will only disclose the minimum amount of data required for the purpose of a valid authority request. Freenow is not allowed to just simply disclose all user data stored about a user. Please limit your request to the user data strictly necessary for fulfilling the purpose of the request.

What is a unique identifier?

In order for Freenow to identify the user or users you are requesting information about, Freenow needs an "identifier". An identifier is a piece of information that is used to uniquely identify an individual. Possible identifiers for a Freenow user can be e.g. account email address, phone number, booking IDs, device IDs, pickup location and pickup time or licence plates. The following information is usually not suitable to act as an identifier for a request: first and last name, age, home address or descriptions.

What do we mean by legal obligation?

Companies are bound by national law and may be obliged to provide certain user data to authorities upon request if there is a legal basis for it in the law of the relevant country. Providing information on the applicable legal obligation or a valid legal basis in your request will help us to process the request more quickly and will lead to a faster response from Freenow.

Why are there so many requirements to request user data from Freenow?

With the introduction of the General Data Protection Regulation (GDPR) in 2018, a company that discloses user data to an authority needs to identify a legal basis for the transmission of the requested user data to the authority (the most relevant here being that Freenow is obliged by law to disclose the data). Also Freenow needs to verify beyond any doubt that the incoming request is legitimate. If Freenow fails to meet its obligations under data protection law, not only would it be possible for a supervisory authority to impose a fine against Freenow but also the individuals about whom user data was disclosed could press charges and sue for damages.

Authority Requests Guidance

General Information

These guidelines provide information to law enforcement officials and other public authorities ('authorities') that seek access to non-public passenger or driver personal records and content ('user data') from Freenow. The guidelines do not create any obligations for Freenow or waive any objections of Freenow in relation to a request or otherwise determine how a particular request will be handled.

Freenow wants to live up to its responsibility to improve the safety of its platform and the individuals that use it. Therefore Freenow has implemented a dedicated process to handle incoming user data disclosure requests from authorities ('authority requests'). To adequately protect the privacy of our users, a team consisting of members from various departments (customer care, data protection, data engineering and more) carefully reviews all incoming authority requests.

Freenow is committed to the privacy of its users and will only disclose user data to authorities in line with applicable legislation and according to the basic data protection principles set out by the UK's and the EU's General Data Protection Regulation (collectively referred to as 'GDPR'). In most cases, it is Freenow's policy to only disclose user data in response to an authority request where Freenow has a legal obligation to do so.

The team supervising the requests will also take reasonable efforts to make sure that the requesting authority has the power to make the request.

Data protection law to which Freenow is subject requires that we adhere to the principle of 'data minimisation' – in the context of responding to an authority request, this means disclosing the minimum amount of user data required for the purpose of the request. As far as possible, the team will also perform a check of whether the requested data is really necessary for the purpose explained in the request. Freenow may provide less user data than has been requested, or no user data at all, if Freenow has doubts regarding the necessity of the data for the purpose described in, or the validity of, an authority request.

Requirements for Authority Requests

Freenow will only disclose user data to authorities if the authority request complies with the requirements explained in this section (provided that Freenow is satisfied that it has a lawful basis to make the disclosure in accordance with applicable data protection law).

General Requirements:

The requirements listed here are mandatory for all authority requests (through all means of communication). All requests must:

…clearly identify the law enforcement agency or official government entity sending the request
... contain a unique identifier associated with the accounts for which the data is requested (e.g. email addresses, licence plates) or an identifier for a specific trip (e.g. pick-up and drop-off location or date and time of the trip);
... be issued by an authority that is entitled by law to submit the request (e.g. a court or the police);
... be issued to the correct legal entity of Freenow (please see here);
... describe the legal basis empowering the authority to request or obliging Freenow to disclose the requested data;
... contain a description of the purpose of the request;
... contain a file or case number to enable proper identification and clear communication;
... contain the details of a contact person for the request in case there are any questions or concerns with the request;
... contain an envisaged date of return in the format DD-MM-YYYY. Please keep in mind that the verification process and the gathering of the data may lead to longer response times.

Authority Requests in Hard Copy:

Authority requests that reach Freenow in hard copy also have to:

... contain a signature of the person requesting the user data
... contain the official stamp of the requesting authority

Online Authority Requests:

Authority requests that reach Freenow in an electronic format also have to:

... be sent by a law enforcement agency or official government entity via an official authority email domain;
… contain the official request as attached document
... contain an official authority electronic certificate

How do I raise a request?

In order to issue an authority request with Freenow please send your request via the means of communication named here:

Online Authority Requests	To ensure the most prompt resolution, authority requests should be sent to: authority@free-now.com
Hard Copy Authority Requests	If you want to submit requests via mail or in person, you can find the address of our respective legal entities in the areas in which Freenow operates here: https://free-now.com/ie/imprint/
Please note:	Check if the displayed information is the correct one for your country. You can change your country selection through the language selection of our website.

Freenow will never provide any user data in person, via telephone or any other communication channel in response to an authority request in the absence of an additional valid written request that legitimises the actions of the requesting authority.

What type of user information can Freenow provide?

The user data processed by Freenow depends on the relevant individual's usage of the Freenow app. Types of data that Freenow may process about individuals include the following. Not all mentioned data categories are processed for every user.

Contact information, such as: first and last name, email address, phone number or home address,
Ride information, such as: pick-up and drop-off location, date, time and duration of the ride,
Payment information, such as: payment method used, tour and renting costs, used vouchers and incentives, or invoices,
Vehicle information, such as: what private hire vehicle (“PHV”), taxi, shared car, scooter, roller or other vehicle was used, plate numbers,
Documentation, such as: driving licenses, taxi licences,
Device information, such as: device IDs, ip addresses and advertising IDs.

Authority requests guidance