A. Purpose and Scope
At some Pied Parker Locations, vehicle inventories are conducted using automated license plate recognition (“ALPR”) technology. This data (hereinafter “ALPR data”) may be used for all or any of the following purposes:
- To verify users and allow access to Pied Parker locations;
- To audit correct vehicle parking fees for all parking-related transactions;
- To identify and track abandoned vehicles;
- To verify overnight vehicle counts;
- To respond to inquiries of law enforcement agencies.
All access to, and retention of, ALPR data shall be managed by the Chief Technology Officer or other designee, who shall be responsible for ensuring all locations are operating the ALPR system within the parameters of the law.
Pied Parker's Chief Technology Officer or other designee shall be responsible for the monitoring of the ALPR system accessed by Pied Parker to ensure the security of the information and compliance with applicable privacy laws. Pied Parker's Chief Technology Officer or other designee shall also be responsible for the correction of data errors of which he becomes aware. Pied Parker's Chief Technology Officer or other designee shall ensure that only authorized personnel with a legitimate business need for such information shall be granted access to ALPR data.
ii. Authorized PARCS personnel
Those with authority to view the ALPR data include:
- Lot checkers - When conducting nightly vehicle inventories, it is necessary for lot checkers to review and enter license plate information into the onboard computerized ALPR system. Lot checkers must verify all images being recorded are accurate.
- Office Coordinators - When reviewing all parking session transactions, it is necessary for PARCS personnel to review any disputed session, by accessing ALPR information to validate the session entry/exit date for the vehicle and verifying transaction for the vehicle parking session.
- Supervisors - Supervisors cover for office coordinators and run reports on a regular basis in order to flag possibly abandoned vehicles. Supervisors also use the inventory numbers to calibrate the lot counts in PARCS on a nightly basis. Supervisors will also call in and request vehicle location information from the office coordinator when assisting lost customers with finding their vehicles.
- Managers - Managers cover for supervisors and office coordinators. Additionally, managers are responsible for handling inquiries made by law enforcement agencies.
- Auditors - Auditors have access to all facets of the PARCS reporting portal. This is necessary to ensure all revenues are being properly captured and recorded and that there is no manipulation of the system. Specifically, auditors will confirm the correct parking fee was assessed for all lost ticket transactions by reviewing the entry date first-hand in the PARCS.
All personnel with access to undergo training on proper use and handling of ALPR data in order to safeguard customer privacy and comply with applicable laws. The Chief Technology Officer or his designee shall be responsible for the development and implementation of training requirements for all authorized personnel.
The Chief Technology Officer or other designee will monitor querying activity via electronic logs to ensure searches are tied to legitimate transactions and other aforementioned business needs.
v. Sales Prohibited
The sale and unauthorized dissemination of customer license plate information is strictly prohibited by company policy. Violations will include disciplinary action up to and including termination of employment or other contractual relationship.
vi. Sharing or Transfer
The Chief Technology Officer or other designee shall develop, implement and monitor the process for and restrictions upon the sharing or transfer of ALPR information to other persons. The process for sharing or transfer of ALPR information shall, at a minimum, include:
- a written request is made for ALPR data which includes: the name of the entity requesting information; the name of the person requesting; and the intended purpose of obtaining the information;
- the request is reviewed by The Chief Technology Officer or other designee;
- the approved request is retained on file.
License plate information collected using the ALPR system will remain on file for a period of 7 years (or less based on the operators policy or upon user request for deletion) and shall be automatically purged from the ALPR system upon the expiration of this period.
ALPR system audits shall be conducted on a regular basis.