PRIVACY POLICY APCOA Parking UK

Background

APCOA Parking (UK) Limited is the main operating company of the APCOA Parking group of companies in the UK. In addition to APCOA Parking (UK) Limited, these companies are APCOA Parking Holdings (UK) Limited, APCOA Parking Services (UK) Limited, APCOA Facilities Management (UK) Limited, APCOA Facilities Management (Harrow) Limited and Park & Control UK Limited. This policy applies to each of these companies. Therefore ‘APCOA’ and ‘we’ are used throughout to refer to all the companies in the Group and each to each one of those companies as it applies to that company.

APCOA takes its obligations about your personal information seriously and is committed to ensuring your personal data is protected. This privacy notice describes how APCOA, in its various roles as both a Controller and Processor, collects, uses and protects your information. APCOA is registered with the Information Commissioner’s Office (ICO).

How we collect your information

The information we hold about you comes from the way you engage with us such as through your participation and contribution in APCOA related activities, taking part in customer research and surveys or product trials. We also collect your personal data if you enquire about our services through our websites, when purchasing, registering, or subscribing to an APCOA service or product.

Images of vehicles and Vehicle Registration Marks (VRMs) are collected via ANPR cameras. Where applicable, VRM data may also be collected and processed through payment systems.
If you have received a Parking Charge Notices (PCN) and are the registered keeper of the vehicle, your data will have been obtained from the Driver and Vehicle Licensing Agency (DVLA) or an international equivalent.

If you are not the registered keeper of the vehicle, your data may have been provided by the registered keeper, a driver or user of the vehicle, a vehicle hire or leasing company, a fleet manager, an employer, or another third party authorised to disclose such information in relation to the vehicle.

We may also collect information about you through our website, through our product applications, via email, the post, over the phone, via Webchat or from discussions with you or from information received from you relating to car park bookings, Parking Charge Notice (PCN) payments, a season ticket, parking permits our provision of a Car Park Management Services or other services to our clients.

The type of information we hold

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data: Includes first name, last name, date of birth, drivers’ licence, company name or similar identifiers.
• Contact Data: Includes address, contact telephone numbers, email address.
• Financial Data: Includes credit card details, bank details and transaction history.
• Transaction Data: Includes details of the services you have acquired from us, payments made by you, and other information relating to the products and services you have purchased from us such as images or your vehicle entering the car park, Vehicle Registration Mark (VRM) and DVLA keeper details.
• Enforcement Data: Includes details such as location, Vehicle Registration Mark (VRM), DVLA keeper details, email address and postal address for appeals, immobilisation number and photograph evidence of the vehicle.
• Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

How we use your information

Who we will share your information with

We may share your personal data with third parties, including our service providers and relevant government authorities, where necessary to perform our contractual obligations, operate our business, and comply with applicable legal and regulatory requirements. Below is a list of the categories of organisations with whom we may share your personal data:
• The DVLA to request details of the registered keeper of the vehicle in order to enforce non-compliance of our car parking Terms & Conditions.
• Third parties such as, Parking on Private Land Appeals service (POPLA) at your request, and Debt Collection Agencies, Bailiffs and Courts in relation to unpaid Parking Charge Notices.
• Our service providers who manage some of our Marketing, Car park bookings, payments, the processing of our Parking Charge Notices, Web services and Group Procurement scheme.
• Business partners where we need to exchange the information to fulfil a parking contract arranged through them or through APCOA.
• Law Enforcement Agencies in circumstances where we have reason to think a criminal act may have been committed.

Our third-party providers are bound by UK privacy law and the terms of the contracts we have with them.

Use of cookies

We may use cookies and similar technologies on our website.

Cookies are small text files that may be stored on your computer or mobile device when you visit our website. Cookies do many different things, such as letting you navigate between web pages efficiently and remembering your preferences.

We use cookies to track your use of our site, but we do not use cookies to make decisions about you or to send you marketing information electronically. Please see our cookie information (which can be accessed by clicking the fingerprint icon in the bottom corner of our website) for more details.

Camera Monitoring Privacy Notice Background

APCOA currently uses CCTV cameras and other camera related surveillance systems such as ANPR and body worn cameras to view and record individuals or vehicles on and around our premises and the areas we have agreed to manage for our clients.

In this Notice we will refer to the CCTV, ANPR and other camera related surveillance systems collectively as ‘Camera Monitoring’ This Notice outlines why we use Camera Monitoring, how we will use that data and how we will process data recorded by such devices to ensure we are compliant with data protection law and best practice.

Reasons for the use of Camera Monitoring

We currently use Camera Monitoring in and around our premises and the areas we have agreed to manage for our clients as outlined below.
We believe that such use is necessary for legitimate business purposes, including:
• To prevent crime and protect buildings and assets from damage, disruption, vandalism and other malicious acts.
• For the personal safety of staff, visitors, and other members of the public and to act as a deterrent against crime including fraud.
• To support law enforcement bodies in the prevention, detection, and prosecution of crime.
• To assist in ensuring the health and safety of staff and others.

This list is not exhaustive and other purposes may be or may become relevant.

Viewing

Images are only viewed by authorised personnel. All staff using Camera Monitoring are given appropriate training to ensure they understand and observe the legal requirements related to the processing of the data that has been collected.

How we use data gathered by Camera Related Surveillance Systems

In order to ensure that the rights of individuals recorded by our Camera Monitoring are protected, we will ensure that data gathered is stored in a way that maintains its integrity and security.

Given the large amount of data generated by Camera Monitoring, we may store video footage using a cloud computing system. We will take all reasonable steps to ensure that any cloud service provider maintain the security of our information, in accordance with industry standards.

Where we engage data processors to process data on our behalf, we ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.

Disclosure of Data Gathered by Camera Monitoring

We may share data with our group companies and other associated companies or organisations, including our clients and shared services partners, where we consider this reasonably necessary for the legitimate purposes set out above.

Images and other data obtained through our Camera Monitoring systems will only be disclosed to third parties where there is a lawful basis to do so and in accordance with our internal data protection procedures.

Data will not normally be released unless satisfactory evidence is provided demonstrating that it is required for legal proceedings, compliance with a legal obligation, or pursuant to a court order.

In appropriate circumstances, we may permit law enforcement agencies or other competent authorities to view, copy, or obtain such data where necessary for the prevention, investigation, detection, or prosecution of crime.

We will maintain a record of all disclosures of such data. Images obtained through our Camera Monitoring systems will not be published online or disclosed to the media except where required by law or permitted under applicable data protection legislation.

Retention and Storage of your information

We will retain your personal information in accordance with legal and regulatory requirements. We will only retain your information while we are actively engaged with you. Where we have had no interaction with for a period of 6 years, will delete your data.

Data from Camera Monitoring will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained will vary according to the purpose for which they are being recorded. For example, where images are being recorded for crime prevention purposes, data will be kept only long enough for incidents to come to light.

Where the images are being used to regulate and enforce parking conditions, the images will be retained until any parking charge has been settled.

In all other cases, recorded images will be kept for no longer than 30 days. The Site Manager or designated senior employee will maintain a log of when data is deleted.

At the end of their useful life and in accordance with our retention policy, all images stored in whatever format will be erased permanently and securely.

Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs and hard copy prints will be disposed of as confidential waste.

Your personal information will be stored on systems owned or operated by APCOA or those of our specific suppliers and will only be stored inside the United Kingdom (UK) or European Economic Area (EEA), or a country approved by the United Kingdom government.

You should be aware, however, that where payments are made using credit or debit card transactions, those payments are governed by the terms of your agreement with your card issuer.

Data Security

Within APCOA, your information will be stored on our secured systems in accordance with APCOA’s Information Security Policy.

Your Rights

You have the right to:
• Right to object to processing of personal data that is likely to cause you, or is causing you, damage, or distress.
• Right to restrict processing.
• Right to have inaccurate personal data about you rectified.
• Request your information be deleted or destroyed and if we can we will, but sometimes we must maintain some records for legal reasons.
• Right to access the personal data we hold about you.

In respect of Camera Monitoring data, please note that we reserve the right to obscure images or mute sounds of third parties when disclosing such data as part of a subject access request, where we consider it necessary to do so to protect the rights of others.

How we will tell you about future changes to this privacy notice

Any changes we make to our privacy notice will be put on our website. Please check for updates from time to time so you are always fully aware of what information is collected and how it is used.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact the Data Protection Officer at dpo@apcoa.com. 

If you are concerned about how we have handled your data, we encourage you to contact us first so we can resolve your concerns. If you are not satisfied with how we have handled your complaint, you can make a complaint to the Information Commissioner’s Office using the contact details below:

By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

By Website: Click Here By Email: Click Here By Phone: 0303 123 1113