Last Updated: July 29, 2024
What Is ALPR: Automated License Plate Recognition technology (“ALPR System” or “ALPR”) utilizes cameras and various processes to capture and store digital images of vehicle license plates, and uses character recognition algorithms to identify license plate characters. An ALPR System creates a searchable computerized database resulting from the data collected by fixed and/or mobile cameras located at various locations. ALPR System data (“ALPR Data”) includes license plate number information as well as the date, time and location when the image or information was collected.
Using ALPR: There are many laws that govern how an ALPR System may or may not be appropriately used by business organizations and law enforcement authorities. This ALPR Policy pertains only to Parking Concepts, Inc. (“PCI,” “we,” “us,” or “our”) and includes PCI corporate affiliates and its/their officers, directors, employees and agents.
Purpose Of This ALPR Policy: The purpose of this ALPR Policy (“ALPR Policy”) is to detail our use of the ALPR System, our authorized users of the ALPR System, and how we use, access, process, share, store, maintain, collect, secure, and retain the ALPR Data that is within our possession or control, in compliance with all applicable federal, state, and local laws.
Applicability Of ALPR Policy: This ALPR Policy pertains only to our interaction with and use of the ALPR System that is deployed at an ALPR enabled parking location that we manage, including our data practices relevant to the ALPR Data that is within our possession or control. Any ALPR Data that is in the possession or control of others, including how those parties make use of the ALPR System, is subject to the respective ALPR policies of such other parties and not this ALPR Policy. Accordingly, be sure to carefully review the ALPR policies of these other parties for how they interact with and make use of the ALPR System including their data practices relevant to the ALPR Data that is within their possession or control. Any third party ALPR related information that we may receive from other third parties (such as law enforcement) is subject to this ALPR Policy. Whether we release any information or data shall depend upon this ALPR Policy, applicable law, and what instructions we may receive from that third party.
Authorized Purposes For Collecting ALPR Data: We utilize ALPR to capture, analyze, and store digital license plate data to enable the rapid identification of vehicles in support of parking operations and compliance activities. ALPR Data may also be used to supplement or replace paper tickets to log the times at which a vehicle enters or exits our ALPR enabled and PCI managed parking locations to determine the fee due upon exit. ALPR Data may also supplement or replace proximity access cards and permit stickers to grant location entry to subscription parking permit holders and to facilitate a more efficient and expedient location exit.
Authorized Purposes For Using ALPR Data: We may use ALPR Data in accordance with applicable law to: (1) calculate parking fees for lost entry tickets; (2) identify and track down abandoned vehicles left in our managed parking locations; (3) verify the count of vehicles parked in our managed parking locations; (4) identify open parking spaces; (5) permit entry/exit to vehicles without need for interaction at the entry/exit gate; (6) respond to inquiries from law enforcement, legitimate third party subpoenas, or inquiries from other legitimate third parties; (7) issue fee, parking violation, or citation notices; and (8) generate various operational metrics and statistical reports internal to our organization and for our own internal business purposes, noting that in certain instances our clients may have access to the same data.
Restricted Uses: We do not process or make the ALPR System or ALPR Data available to individuals for any personal, or non-commercial purposes. We do not sell ALPR Data. We only use the ALPR System to collect license plate data from within public view. Any ALPR Data that we may access shall not be used by us to harass, intimidate or discriminate against any individual or constitutionally protected group.
Management Of the ALPR System: The ALPR System that is deployed at any parking location that we manage is primarily installed and managed by our trustworthy independent third-party service providers who have undertaken responsibility for safeguarding the ALPR Data that is within their possession and control, including its collection, use, security, integrity, dissemination, retention, monitoring and destruction. Our trustworthy independent service providers have also assumed responsibility for ensuring that their authorized users of the ALPR System operate the ALPR System legally and in accordance with the terms of their respective ALPR policies.
Training: All of our authorized users of the ALPR System (including our employees and any contractor that we may hire to serve as one of our authorized users) shall receive training prior to being granted access to the ALPR System and/or ALPR Data in order to safeguard customer privacy and comply with applicable laws . A record of all completed training is maintained by us and/or by our independent trustworthy service providers. The Senior Vice President – Innovations or their designee shall be responsible for the development and implementation of training requirements for all authorized personnel, and assumes responsibility for the implementation of this ALPR Policy.
Access: Our authorized users with access to ALPR Data include staff personnel, employees and contractors (if applicable) with an operational or departmental need to specifically oversee such a system and/or are responsible for parking operations and enforcement. The respective PCI manager deploying an ALPR System is the custodian and head administrator of the ALPR System and its operation. The only individuals with access and the ability to query data in the system are:
• Facility Managers, and their designee(s)
• Program Managers, and their designee(s)
• Assistant Parking Managers
• Parking Supervisors
• Auditors
• IT Personnel
• Accounting Administration Personnel.
Logins and queries may be stored and monitored, and may contain the following information:
• Username
• Date
• Time
• Purpose of query
• License plate and other criteria used to query the system.
This data may be stored and monitored by each respective PCI manager or their designees. License plate information is only referenced against vehicle parking databases or other third-party databases where the third party has legitimately requested that we do so for legal purpose, such as for law enforcement or for debt collection purposes. See section entitled “ALPR Data Requests from Third Parties” below.
PCI or their designees run periodic audits to ensure access to the ALPR System is restricted to authorized users only. When requested by an individual to verify ALPR Data in our possession, we will take commercially reasonable measures to review ALPR Data to ensure it is accurate and correct errors where necessary.
What ALPR Data Is Collected: The following information may be collected by the ALPR System but not all of the following information may be received, accessed by, used or retained by us:
• Vehicle license plate image captured
• Vehicle license plate number
• Vehicle license plate state
• Date
• Time
• Location
• Payment and parking device information.
Data Storage & Data Retention: ALPR Data is generally sent to and stored in the databases of our trustworthy independent third-party service providers. Some of the ALPR Data that is accessed by PCI may be stored in our database when such data is needed to process a parking related transaction at one of our parking locations that we manage. This data is used by the ALPR System, for example, to allow parking customers to gain entry to parking for which their permit is valid and to exit without having to provide payment. The permit holder’s license plate number may be used to supplement or replace proximity access cards, plastic hang tags, stickers, and other permit materials.
The length of time that ALPR Data in our possession or control will be retained or stored in our databases varies depending on the parking lot location and such data may be destroyed or overwritten at any particular parking facility location if that location’s data storage capacity has been exceeded, but all such data is also centrally stored and maintained indefinitely by PCI in a transactional format. Notwithstanding the above, ALPR Data shall not be retained or stored after 5 years.
In any event, we may retain ALPR Data when lawfully required to by court order, to comply with a pending litigation, in response to a legitimate inquiry from law enforcement or under circumstances where we need to continue to retain such data for our own operational, research, statistical or business purposes, noting also that ALPR Data not in our possession or control may be stored in third-party ALPR cameras, equipment and connected databases pursuant to a third-party’s own data privacy policies and procedures. The data records stored on our ALPR servers do not include photographs of the vehicle (either close-up of the license plate or context photo of the rear or front of the vehicle) but instead are limited to the alpha numeric license plate information and accompanying date, time, and location in the field. Such records do not directly identify a particular person. Please consult the ALPR policies of our independent service providers for information about how long our ALPR service providers retain the ALPR Data in their databases.
Security: We and our independent trustworthy ALPR service providers use administrative, operational, technical and physical safeguards to protect the ALPR System and ALPR Data from unauthorized access, use, destruction, modification or disclosure including implementing the following safeguards:
Technical: All information is encrypted to protect any personally identifiable information. The ALPR System workstations and servers shall be updated with the latest security patches on a regular basis. Antivirus protection will be utilized, and log files will be periodically reviewed. The ALPR Data shall be secured, encrypted, and backed up regularly.
In the very unlikely event of a data breach that constitutes a violation of any applicable law, proper data breach notifications will be made in accordance with applicable law.
Releasing ALPR Data: We will not share ALPR Data that is within our possession or control with any commercial or private entity or individual, other than as necessary to conduct our parking management operations or as required by applicable federal, state or local law. We include confidentiality provisions in our agreements with our contractors to prohibit any use or distribution of ALPR Data within our possession or control for any purpose other than the authorized uses under this ALPR Policy. ALPR Data gathered or collected and records retained regarding this data will not be:
• Sold, published, exchanged, or disclosed for commercial marketing or promotional purposes
• Disclosed or published without authorization or
• Disseminated to persons or entities not authorized to access or use the data.
ALPR Data Requests from Third Parties: We shall provide ALPR Data to a federal, state, or local law enforcement or other governmental agency upon legitimate inquiry or if a warrant or other court order is issued and served. ALPR Data gathered shall not be disclosed to the public or in a civil matter unless such disclosure is required by law or court order. Further, any specific request for ALPR Data that we may receive from a third party is always subject to our review and approval. If we were to accept and approve such a request, we would require that the third party certify compliance with all applicable law and adopt ALPR policies and practices consistent with this ALPR Policy.
Enforcement: Violation of this ALPR Policy by any PCI employee, retained contractor, or other PCI authorized user, may lead to suspension or termination of that user’s access to the ALPR System and ALPR Data, and potentially suspension or termination of employment or contract retention.
Changes To This ALPR Policy: This ALPR Policy may be amended from time to time in order to account for new PCI company-wide or facility specific policies and procedures and/or new changes in the law, so please be sure to periodically check this ALPR Policy for any new updates. We also reserve the right to apply such ALPR Policy amendments to any ALPR Data that may have been collected prior to the implementation of any ALPR Policy amendment.
Contacting Us: If you have questions regarding this ALPR Policy, contact us via email at support@parkingconcepts.com.