12.4 Automatic Number Plate Recognition (ANPR)
12.4.1 ANPR – is normally a standalone system with dedicated cameras capable of capturing and recording images of vehicle number plates that may be later retrieved for the following purposes:-
- control of vehicle access;
- traffic management;
- detection of criminal activity;
- parking management; and
- monitoring vehicle related health and safety issues.
12.4.2 Where ANPR is owned and operated by a car park management service provider under contract, that organisation will be a data controller in its own right and solely responsible for Data Protection Legislation compliance.
12.4.3 Right to be Informed – dedicated ANPR information signs should be installed at vehicle entry points, although it may be appropriate that this information is incorporated into CCTV information signs. As a matter of best practice, the signs should instruct the reader how to access the data controller’s Privacy Policy.
The data controller’s Privacy Policy should refer to the use of ANPR.
12.4.4 Subject Access Request – refer to section 8.1.
12.4.5 Consent – due to the lawful basis of this processing consent would not be required.
12.4.6 Archive Retention – the recognised standard is 30 days, however in setting this parameter consider how long it is likely to be before you become aware of an incident. The shorter the archive retention, the less potential impact right of access and right to erasure requests will have on the business.
Public car park access and egress transaction data should not be retained unless relating to a delinquent issue and a recording is required for evidential purposes.
Privacy – access to ANPR data shall be password protected and managed on computer devices identified by unique reference numbers, logged in a Controlled Data Register. The data must be deleted at the end of the archive period.
Process – to be documented using the VeriFi Compliance Manual or VeriFi EIDOS Management Information System.
