This privacy notice explains how Smart Parking Ltd uses your personal data (i.e. information about you and your vehicle) in order to provide you with parking services under our contract with you. These terms should be read together with our parking and payment terms, which can be found here www.smartparking.com/parking-terms-and-conditions
These terms also explain how we comply with the General Data Protection Regulation and the Data Protection Act 2018; we will refer to these laws as ‘Data Protection Law’.
This privacy notice also explains how we use your personal data on data collection only sites, in order to provide managed services.
This privacy notice includes the following information to help you understand clearly how your data is being used:
SMART PARKING Ltd (SC138255) is a company registered in Scotland and can be contacted at Unit 43, Elmdon Trading Estate, Bickenhill Lane, Birmingham, B37 7HE. Our Data Protection Officer can be contacted by emailing email@example.com.
When you enter, remain and exit a car park operated by us, we take photographs of the vehicle and registration by Automatic Number Plate Recognition (ANPR) and CCTV cameras. In car parks where ANPR and CCTV cameras are not in operation our parking wardens are present to deter criminal activity and they may take notes and images about your vehicle and your activity in the parking area. The data gathered by cameras or parking attendants is needed to determine your compliance with the parking and payment terms of your contract with us.
Your personal data is being obtained, retained and processed, depending on the category of user you are of our site. We also use our cameras to detect and deter criminal activity.
Under Data Protection Legislation you have the following rights:
Please note that you have the right to request the above, but under data protection law we must; confirm who you are before providing information and; provide you with an explanation if we do not agree with your request. So if you do make the request we will tell you if the request has been granted or not.
You have the right to submit a Subject Access Request and this can be done by emailing firstname.lastname@example.org or in writing to our Data Protection Office at the above address. We will need to confirm who you are obtain proof of your identity before providing you with information we may hold about you.
1. Where there has been no breach of the parking contract
As a compliant user of this Private Land, the personal data we obtain is your vehicle registration number. We may also capture images of the vehicle, occupants or bystanders. A full list of your Rights under data protection law are summarised above. Where your data is obtained it will be retained for 36 months only in order to be able to cross reference registration numbers for discrepancies, retaining this data in this way enables us to properly and fairly manage the car park which sometimes means cancelling Parking Charges. After this time, we then erase your registration and any other images from our records.
2. Unpaid Parking Fee and where a parking charge becomes due:
The personal details we may obtain from the DVLA for both Camera and Parking Warden Windscreen Parking Charges include:
Your data will be held for sufficient time to enable the fee or outstanding parking charges to be settled, by you or another person and resolve any dispute. However, your data will not normally be held for longer than 6 years in such circumstances. In some circumstances your data may be held for longer than 6 years, examples of this are:
If you decide to challenge a parking charge and we reject your challenge, we will provide you with a unique reference code to be used with POPLA, the Parking on Private Land Appeals Service. This is to allow you to contest the charge with an independent adjudicator who will be provided with your data.
4. Managed Services
On sites where we are use ANPR cameras, for data collection purposes only, and where are not enforcing and not relying on a contractual basis, we retain the VRN and any images for a period of 90 days. This data is kept long enough to ensure we can process the data into raw site statistics, and provide effective managed services, in order to protect our legitimate interests.
5. Data Analytics
We may use your individual vehicle activity, in order to derive raw data values of total entries and total exits of all vehicles, or vehicle types that have entered a given car park on a given day. It should be noted that we don’t analyse individual data subject’s activity but analyse the overall site activity. This derived data can no longer be linked to any data subject and is therefore retained for as long as is needed in order to provide effective managed services.
Your personal data may be shared with:
Other than the list above we do not share information about you or your vehicle with any other third party. Where data is transferred outside the EU we have ensured that those from the list above accessing the data have the appropriate safeguards in place and are subject to an appropriate supervising authority.
If you require more information about items raised in this notice please contact us or you may wish to ask or complain to the Information Commissioner’s Office via the ICO website, www.ico.org.uk although please raise any concerns with us first by emailing email@example.com.