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 FREE NOW. The guidelines do not create any obligations for FREE NOW or waive any objections of FREE NOW in relation to a request or otherwise determine how a particular request will be handled. 

FREE NOW wants to live up to its responsibility to improve the safety of its platform and the individuals that use it. Therefore FREE NOW 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.

FREE NOW 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 FREE NOW's policy to only disclose user data in response to an authority request where FREE NOW 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 FREE NOW 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. FREE NOW may provide less user data than has been requested, or no user data at all, if FREE NOW has doubts regarding the necessity of the data for the purpose described in, or the validity of, an authority request.

Requirements for Authority Requests

FREE NOW will only disclose user data to authorities if the authority request complies with the requirements explained in this section (provided that FREE NOW 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 FREE NOW (please see here);
• ... describe the legal basis empowering the authority to request or obliging FREE NOW 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 FREE NOW in hard copy also have to:

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

Online Authority Requests:

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

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

How do I raise a request?

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

FREE NOW 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 FREE NOW provide?

The user data processed by FREE NOW depends on the relevant individual's usage of the FREE NOW app. Types of data that FREE NOW 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.