Travelling with your Debit Card

^{¹ Arriva, Connexxion, EBS, GVB, HTM, Keolis, NS, Qbuzz and RET. See ovpay.nl for the most up-to-date overview.
² Maestro, Mastercard, VPAY and VISA. See ovpay.nl for the most up-to-date overview.}

When you check in and out with your Debit Card, you will enter into a transport agreement to which the NS Terms and Conditions apply. When you use your Debit Card as a Ticket, the 'OVpay Terms Conditions for Checking In/out with your Debit Card and Credit Card'also apply. In addition, the relevant terms and conditions will apply when you use a discount product or discount profile. If you travel with Intercity Direct, then the Intercity Direct Product Terms and Conditions will also apply.

When you check in or out with your Debit Card, NS has to Process your Personal Data. This lets you travel with NS and pay using your card. NS and Translink may also provide services. If you do not want to share the necessary personal data with NS or Translink, you will not be able to travel and pay using your Debit Card and you will have to use another type of Ticket.

The processes have been set up on the basis of Privacy by Design. This means that Translink and the carriers have designed and established the system in order to protect your privacy as a traveller as effectively as possible. 

The capitalised terms below have a fixed definition, as stated in the glossary at the end of our privacy statement.

Pseudonymisation, re-identification and token use

Immediately after you check in, the unique identification number ('PAN') of your Debit Card is Pseudonymised. This is done by giving each card its own unique number, called a token. These unique tokens are used for various purposes such as travel, payments, services, inspections and summary reports. 

Translink has an administration system in which Translink registers tickets and other administrative issues on behalf of Carriers, and calculates the price of a journey as well as the total cost of your travel for the whole day. This system assigns each Carrier its own unique identification numbers for the tokens. As a result, Carriers have no insight into the travel patterns of trips with other Carriers made by a traveller. 

Without additional information, Pseudonymised data cannot be traced back to your Debit Card data. Pseudonymisation serves to reduce the risks of Processing the Personal Data of individual travellers. By combining Pseudonymised data with other data, an organisation may be able to identify which Debit Card belongs to the pseudonym. This may then make it possible to view the travel history associated with a Debit Card. 

The Carriers and Translink have made agreements with each other to prevent this risk of re-identification.

A.Travelling with your debit card

When you check in with your Debit Card, the card reader reads Technical Data from the card. We check whether the card can be used to travel and notify you via the card reader. Presenting your card to a card reader is known as a 'tap'.

If you are allowed to travel with your Debit Card, Personal Data is sent from the respective Carrier's card reader to Translink when you check in or out. In addition to the Technical data, the data package also includes the date, time and the stop or station where you checked in or out. Translink records all check-ins and check-outs, pieces together your trips and determines the fares. Your journey will be compiled and the fare will be calculated using these data, along with any relevant additional data, discount products or discount profiles. 

Please make sure that upon checking in and out, you present your card to the reader separately, rather than from inside your wallet. This will help ensure that you only check in and out with the intended card, so you do not inadvertently get charged too much for your trip.

First time travelling with your Debit Card

The first time you check in with your Debit Card, an automatic check is performed to determine whether your Debit Card is suitable for public transport travel in the Netherlands. This check is also performed if you check in after not having used the Debit Card to travel for a period of 90 days. 

Translink also checks with the Bank to see whether your Debit Card is blocked. If it is, the public transport travel function on your Debit Card will be blocked so that you cannot use it for travel. This is a decision the Bank makes. The Carriers and Translink cannot do anything to change this.

Debit Card validity check

Every time you check in with your Debit Card, Translink's alert list is checked to see whether the card in question has been blocked. This list is managed by Translink and distributed to Carriers. Translink will add your Debit Card to this list if 

• the Debit Card you used for public transport is on an alert list
• the Debit Card you used for public transport is on an alert list managed by the Bank or bunq, e.g. if it has been registered as lost or stolen;
• the Debit Card or was declined, for example because you had insufficient funds on your Bank Account.
• you used a discount product or profile without meeting the applicable terms or conditions.

B. Payment

Paying with your Debit Card

When you check in and out with your Debit Card, Translink calculates the fares for the trips that you make. Translink processes payments for your trips together with EMS (European Merchant Services B.V., "EMS"), www.emspay.com) and your bank. In the night following the Travel Day on which you travelled, EMS will present the full amount due for all trips made on one Travel Day to your Bank.In order to process the payment, Translink sends the Technical data and the Payment Reference to the Bank.

If the payment is successful, an entry will appear on your digital or physical Bank Account statement and you will receive a unique Payment Reference for each day that you travel. If money is debited from your account twice on the same day (because you exceeded a limit), you will find two Payment References, each beginning with NLOV. Unique Payment References are made for each Travel Day and are always preceded by the letters "NLOV". You can find your digital account statement by logging on to your secure Banking Environment. 

If you share this payment reference and the corresponding amount with another person or organisation, they can also gain insight into the trips you made.

Your outstanding balance will be settled during the Travel Day if it exceeds a certain ceiling to be determined by Carriers. The fare due will then be debited directly from your Bank Account. After successful payment, any subsequent trips you make will be charged at the end of the Travel Day, unless you reach the spending ceiling again before the end of the day. Each direct debit is linked to a unique Payment Reference.

Summary Reports

Each Carrier receives daily summary reports from Translink to verify the accuracy of their own transactions and payments. These reports contain transactions (e.g. every check-in or check-out), journeys (paired check-ins and check-outs) and payments within the domain of the Carrier in question. Translink also ensures that each carrier receives payment for the trips you make every day using your Debit Card. 

Unsuccessful payments

If you are unable to pay with your Debit Card, for example because there were insufficient funds in your account, Translink will temporarily block the travel feature on your Debit Card. You will then no longer be able to travel by public transport with your Debit Card until the outstanding amount is paid.

Paying an outstanding amount for a Debit Card

Over a period of 62 calendar days, the central administration system will make repeated payment requests to debit the amount due from your account. If the payment is successful, the block will be lifted. 

You, as traveller, can also pay the due amount during this period or after it.

• You can do so by tapping your Debit Card or on a card reader on the check-in/check-out device of any Carrier. Translink will then make a payment request to your Bank.
• You can also pay the amount due via the OVpay app. EMS will then make a payment request to your Bank. In both cases, if the payment is successful, you will be able to travel using your Debit Card around 15 minutes later.

Travel block

You can check whether you have been blocked from using your Debit Card's travel function by tapping it on a Carrier’s card reader and checking the message on the display or by contacting OVpay customer service.

If you are unable to travel with your Debit Card, you can always use another Ticket to travel by public transport.

C. Service

We understand completely that you may have questions about matters such as a journey, costs that have been charged, or a missed check-in or check-out. You may also want to view your recent travel history. You can check by requesting your travel history via the OVpay website, OVpay app and OVpay Customer Service. (The OVpay app has its own privacy statement; you can find it in the OVpay app or OVpay website under 'Privacy'). You can also link your Debit Card to your MijnNS account in order to receive service and information for journeys made on NS.  Please contact NS Customer Service for any questions you may have about NS services. 

In order for us to be able to help you, you will need the Payment Reference Number for the Debit Card and the amount debited from your account. We do not know your Debit Card number and we cannot search for your IBAN either. 

App and website

You can link one or more of your Debit Cards to the OVpay App, which you can download from the app stores. There are a few different ways to do this. First, create an account and password in the App. You can then link the Debit Card to the app using a Payment Reference Number and the associated amount in the app, but only up to 31 days after you travelled and made a payment. 

Another way to link your Debit Card to the OVpay app is by entering the PAN and expiration date of your Debit Card or in your online account. You can then travel using your card. You can also link the OVpay app to your Debit Card by entering the IBAN and Debit Card number in the online account, and then using the Debit Card to travel within the next 60 days. 

In your online account, you can see whether you've checked in or out, view the prices and payments for your journeys, the payment status, and any blocks on your Debit Card. The OVpay app also allows you to correct missing check-ins and check-outs, and pay any amounts owed.

In a Carrier's account environment (web or app, if available), you will only be able to view trips made with that Carrier with your Debit Card, again for the past 18 months. You can also use the OVpay app to choose to receive notifications when you check in or out, and about the outstanding amount.

On www.ovpay.nl, you can enter a Payment Reference Number and the corresponding amount to see a list of trips linked to that specific payment. You can also correct a missed check-in or check-out with NS on this website. 

If your trip with NS was delayed, you used your Debit Card, and you are eligible for compensation based on the ‘Delay Refund' scheme, you can submit a refund request using the web form atns.nl. Please remember to include the payment reference number and amount.

Customer Service

For questions about travelling with a Debit Card, please contact NS Customer Service or OVpay Customer Service. Customer Service employees do not have access to your Debit Card data. 

An employee will always explicitly ask for your data if this is necessary in order to answer your questions. Depending on your question, we may ask you for your Payment Reference Number and the corresponding debited amount.

D. Inspection

Everyone using public transportation is required to have a valid Ticket. If you check in with your Debit Card, your Ticket will be linked to that Debit Card through a digital record by Translink. NS employees regularly perform ticket inspections in trains and at stops and stations. In the process, they may also check whether you are travelling with a valid discount product or discount profile. If an NS employee comes to check your Ticket, you must tap your Debit Card on the card reader.

In order for NS employees to be able to serve/help you, they will explicitly ask for your approval. The NS employee can then view the last 10 actions performed with your Debit Card on their device (up to a maximum of 62 days ago). This data is displayed on the device for a maximum of five minutes and disappears the moment another Debit Card is tapped on the card reader. 

The NS employee will be able to see whether you are using a discount product. This product or profile will only be displayed if it applies to your current trip. In all other cases, the NS employee will not be able to see this data.

If you used incorrect data for your discount product or profile, the NS employee can block the discount profile or product in question, barring you from future use. You can update your data in the OVpay app or by contacting the OVpay customer service, after which you will be able to use the discount profile or product again.

Basis for Processing

If you check in and out using the Debit Card or Credit Card with NS, the basis for Processing Personal Data is performance of a contract. This concerns the transport agreement to which the NS Terms and Conditions and the OVpay Terms Conditions for Checking in/out with your Debit Card and Credit Card apply.

For setting up notifications in the OVpay app for checking in and out, the basis for processing is your consent.

For Translink to manage alert lists and distributing them to the Carriers, the basis for processing is legitimate interest.

Automated decision-making

Automated decisions are made in two cases. 

1. Fare due

Passengers must always pay the fare due. If your payment cannot be processed, the travel function on your Debit Card will automatically be blocked. You will then be able to check out for your current journey, but will no longer be able to check in for a new journey. You can appeal an automated decision that causes your Debit Card to be blocked. You can do so by contacting OVpay customer service. They will determine why your Debit Card was blocked and will unblock it if appropriate.

2. Debit Card blocked by bank

If a Debit Card used on public transport has been flagged by a Bank as stolen or missing, or if the Card has been blocked by the Bank for any other reason, the Card’s travel function will also be blocked automatically. This is part of the general terms and conditions for the use of your Debit Card as agreed with your Bank.

The Carriers and Translink cannot change this block. For questions about this, please contact your Bank.

Your Personal Data is Processed by: NS and Translink. NS, the other Carriers and Translink are jointly responsible for processing Personal Data relating to travel using your Debit Card. These agreements are set out in a Cooperation Agreement between the public transport companies and Translink. The shared responsibilities for processing data pertain to the following processes and relevant personal data:

Tapping (checking in and out)

Legal basis: performance of a contract

• Purpose: Checking Debit Card status and tap validation.
• Personal Data: Technical Card data (PAN, PAN serial number and expiration date); Tap data.
• Retention periods: up to 24 hours.

Processing taps (transaction processing)

Legal basis: performance of a contract.

• Purpose:
  • Processing taps.
  • Qualification of taps: tap in/tap out/tap for settling outstanding debt.
  • Compiling trips based on check-ins/check-outs (trip transaction data); determining fares; preparing trip transaction data/tap for settling outstanding debt.
  • Dividing journeys into segments and creating synthetic segments per carrier, so that the segments can be allocated to the correct carrier and the price of the journey can be calculated.
• Personal data: Technical Card data (PAN, PAN serial number and expiration date); Pseudonymised tokens; trip transaction data.
• Retention periods: 18 months.

Central traveller support (self service) with or without service account

Legal basis: performance of a contract

• Purpose:
  • To provide insight into trip transactions, payment transactions and outstanding debt via the OVpay website and OVpay app;
  • To facilitate missed check-outs via the website, OVpay app,   or OVpay Customer Service.
  • To purchase personal products, including discount products, when travelling with a Debit Card.
• Personal data: Payment Reference Number; Payment Transaction Data;  Outstanding debt;  Trip Transaction Data; Pseudonymisation tokens, name or name, date of birth and/or passport photo.
• Retention period: until service has been provided. No data is stored on the website or in the OVpay app after the data is no longer needed for a discount product or profile.

Decentralised passenger support (self service) with service account at public transport company

Legal basis: performance of a contract

• Purpose: To provide data subjects with insight into the following via the website/app of the public transport company in question:
  • trip transactions and payment transactions with the public transport company in question (from the past 18 months);
  • outstanding debt and the underlying transactions (if any) with other public transport companies.
• Personal data: Payment Reference Number; Payment Transaction Data; Outstanding debt; Trip Transaction Data.
• Retention periods: Until service has been provided. No data will be kept on the website/in the app.

Ticket inspection

Legal basis: performance of a contract

• Purpose:
  • Based on check-in/check-out with Debit Card. Checking whether a passenger has a valid electronic public transport ticket while using public transport; and checking the validity of the respective discount profile and/or product if applicable;
  • If no valid check-in or check-out records are found, checking the last ten public transport transactions with the same Debit Card to determine follow-up action for public transport company.
• Personal data: Technical debit card data (PAN, PAN serial number and expiration date); Pseudonymised tokens; trip transaction data, product data; name or name, date of birth and/or passport photo.
• Retention periods: Data will be automatically deleted as soon as the inspection device has received the response that the Debit Card was/was not tapped in/out and 5 minutes have passed or when a subsequent card is presented for inspection or when the inspection (app) is closed.

Mobile service for travellers

Legal basis: consent

• Purpose: Ticket inspector can scan a Debit Card at a traveller’s request to provide information about their last ten public transport transactions with the same card (still under development as of July 2022)
• Personal data: Technical card data (PAN, PAN serial number and expiration date); Pseudonymised tokens; trip transaction data.
• Retention periods: Data will be automatically deleted as soon as the inspection device has received the response that the Debit Card was/was not tapped in/out and 5 minutes have passed or when a subsequent card is presented for inspection or when the inspection (app) is closed.

Compiling and publishing reports about travel transaction processing

Legal basis for processing: Translink's legitimate interest; Carriers' legitimate interest and Carriers' legal obligations

• Purpose: Ensuring the integrity of the public transport system (e.g. transaction validation); administration of carrier contracts, balancing transaction accounts, and facilitating financial administration and reporting.
• Personal data: Trip transaction data (e.g. check-in/check-out; date/time; location; means of transportation; trips and fare per trip); Pseudonymised tokens.
• Retention period: 18 months (justified interest); 7 years (legal obligation). 

NS, the other Carriers and Translink use the services of Processors, for which we always make written agreements with external parties (such as IT suppliers) that Process Personal Data on our behalf. We do this by entering into what is known as a 'processor's agreement' in which we set forth, among other things, agreements regarding the security of your Personal Data and the use of the Personal Data.

Translink uses the services of EMS to process the payment with your Bank. In doing so, Translink provides the Technical Card data and the Payment Reference Number. EMS processes this data in its capacity as a Processor.

Translink makes use of the services of iProov to create passport photos in the OVpay app. IProov processes this data in its capacity as a Processor.

In addition, the Carriers and Translink are in some cases required by law to provide your data to third parties, e.g. in the event of a court order.

NS, other Carriers and Translink protect your Personal Data, for example against unauthorised access, loss or theft. All parties have a policy to organise payment for public transport by Debit Card according to a standard, suitably secure level. 

The Carriers, Translink and bunq abide by the PCI DSS for securing Technical data. This is an international security standard whose purpose is to protect payment card data and prevent unauthorised use of card data and the resulting damages.

NS card readers and the Translink central administration system only Process pseudonymised Technical data.

If you have any questions about the Processing of your Personal Data in connection with travel using a Debit Card, please get in touch with the NS and Translink points of contact.  

In principle, NS and Translink can only answer specific questions if they have access to your Debit Card details. If you have created an account in the OVpay App, linked your Debit Card to this account, and provided your data, Translink can also use this data to help you. Before you can view your trip history with a Debit Card, you must provide the Payment Reference Number and the corresponding amount.

For general questions about travelling with a Debit Card, please contact OVpay customer service on 0900-1433 (standard call charges apply) or using the OVpay contact form.

For specific questions about NS services, please contact NS Customer Service  through one of the specified contact channels, preferably chat, so that you can include any screenshots and be assisted more easily.

If you would like more information about how NS or Translink deals with your Personal Data, please contact the Data Protection Officer in both organisations.

• For NS: fg@ns.nl
• For Translink: fg@translink.nl

Exercising your rights

If you wish to exercise your rights, please notify NS, Translink's Customer Service or Translink's Data Protection Officer, see contact details above.

We may use terms that you are not yet familiar with in the context of travelling with your Debit Card. To help you out, we have listed these terms and what they mean here.

• General Terms and Conditions for local and regional public transport: the Terms and Conditions for the Use of Public Urban and Regional Transport by Bus, Tram, Light Rail, Metro and Regional Public Transport by Train.
• App: a mobile application developed and offered by an individual Carrier or by Carriers and Translink together (under the name OVpay) that enables Passengers with a Debit Card to access their online account, link their Debit Card to their account and thus easily view their trip and payment history, and submit service requests, among other things. The use of an App is subject to the terms of use of the App in question.
• AVR-NS: Nederlandse Spoorwegen's Terms & Conditions for the transport of Passengers and Hand Luggage.
• Bank: a financial enterprise offering payment services and the institution holding the Bank Account to which the Passenger's Debit Card used for public transport is linked. In the section below, a Credit Card Company or other regulated financial enterprise is considered to be a financial enterprise that offers payment services and that issued the Debit Card to you.
• Debit Card: a contactless card issued by a financial enterprise that allows you to use and pay for public transport by checking in and out at the designated card reader at the station, at the stop or in the vehicle.
• Payment Reference Number: a code consisting of a combination of fourteen letters and numbers. A unique reference number is assigned to each payment. This code is linked to the amount debited from your Bank Account when you pay with a Debit Card.
• Joint Processor: If two or more Processors jointly determine the purposes and means of the Processing, they are considered Joint Processors under the GDPR.
• Personal Data: any information about an identified or identifiable natural person as referred to in the GDPR.
• Pseudonymisation: the Processing of Personal Data in such a way that the Personal Data can no longer be linked to a traveller without the use of additional data, provided that this additional data is stored separately and that technical and organisational measures have been taken to ensure that the Personal Data is not linked to an identified or identifiable traveller as referred to in the GDPR.
• Travel day: a period starting at 00:00 and ending at 03:05 the next day.
• Account: an electronic cash account that is not subject to a licensing requirement and is not supervised by De Nederlandsche Bank N.V. or the Netherlands Authority for the Financial Markets. 
• Technical data: this technical data consists of the numbers of the Debit Card, namely the PAN, the PAN sequence number and the expiration date of the card. The PAN is a unique card identification number. The PAN sequence number is stored in the chip of the Debit Card and is not visible.
• Translink: the organisation that registers Tickets, collects fares, collects and settles payments on behalf of Carriers, provides services to travellers, and more. Trans Link Systems B.V., has its registered office and principal place of business in Amersfoort. 
• Ticket: the ticket that provides valid access to trains, buses, trams and metros and is purchased by the Traveller by checking in with NS for each journey using the Debit Card that they use for public transport. A Ticket is only valid if all the requirements stated in the Terms and Conditions of Urban and Regional Transport (when travelling with urban or regional carriers) or the AVR-NS (when travelling with NS) are met.
• Carrier(s): the Dutch public transport companies mentioned on the OVpay.nl website.
• Processing: an operation or set of operations relating to Personal Data or a set of Personal Data, whether or not carried out through automated processes as referred to in the GDPR.
• Processor: a natural or legal person, government agency, department or other body that processes Personal Data on behalf of the Controller as referred to in the GDPR.
• Controller: a natural or legal person, government agency, department or other body who/that, alone or jointly with others, determines the purposes and means of the Processing of Personal Data as referred to in the GDPR.