This Data Protection Policy ensures that National Parking Enforcement Ltd:
Complies with data protection law and that we follow best practice
Protects the rights of staff, clients and partners
Is transparent about how it stores and processes individuals’ data
Protects National Parking Enforcement Ltd from any data breaches
National Parking Enforcement Ltd is the named data controller for the purposes of the Data Protection Act 1998 for all personal data applied for or provided. National Parking Enforcement Ltd is also the payment processor for and on behalf of the data controller (for the purposes of the Data Protection Act 1998).
Drivers or keepers of vehicles who use our websites to make payments or appeal parking charge notices may be required to complete or submit personal data. By doing so, the driver or keeper agrees and consents to us collecting and processing personal data provided to our company. By providing this data either verbally or electronically the driver or keeper also agrees to this data being shared with:
Our authorised and nominated Payment Processor for processing any online payments or payments via electronic telephone payment providers
The DVLA (Driver Vehicle licencing Agency)
The IAS (Independent Appeals Service)
Credit Reference Agencies (for the purpose of ensuring we are writing to you at your most recent correspondence address, if you have not replied to other correspondence).
Our nominated Debt Recovery Agents (in relation to unpaid Parking Charges)
Your personal information and data provided to us is subject to confidentiality and will not be disclosed to any other parties without your prior consent. In certain circumstances, the Data Protection Act allows personal data to be disclosed to the Police without the consent of the data subject. Under those circumstances, National Parking Enforcement Ltd will disclose requested data. The data controller will ensure the request is legitimate, seeking assistance from directors and from the company’s legal advisers where necessary.
We will not ask you for any more information than we need, and we do not keep your information for any longer than we are required to.
We take reasonable steps to keep your details up to date and accurate. Please bear in mind that we may hold your records after your appeal has been considered as we are required to have an effective audit trail and to comply with regulatory and legislative requirements.
The Data Protection Act 1998 gives you the right to access information held about you. You can access personal data we have about you by writing to National Parking Enforcement Ltd, The Studio, St Nicholas Close, Elstree, Hertfordshire WD6 3EW. An administration charge of £10 is payable to cover the cost of providing you with this information.
National Parking Enforcement Ltd protects your personal data and information by having stringent security systems and procedures in place that will assist in preventing possible breaches. Unfortunately, due to the nature of internet networks, the transmission of information via the internet is not guaranteed to be completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
This privacy statement has been produced in accordance with the Data Protection Act 1998 and applies to all personal data, as defined in the Act submitted when you click on the “to Appeal your Parking Charge Notice” button on this website.
Use of the Information
When you make an appeal via the “Appeal your parking charge” button, you accept that National Parking Enforcement Ltd will collect and process personal data you supply. This information may include:
For an Appeal: the parking charge reference, the vehicle registration number, your capacity e.g. driver, registered keeper, hirer/leaseholder or other, your name, postal address, email address and telephone number, the details of the appeal and any uploaded evidence. These details will be used for the purpose of progressing your parking charge to cancellation or payment and may be shared appropriately to do so, and for auditing purposes.
Information supplied to us is subject to confidentiality and will not be disclosed without your prior consent other than in line with this purpose, whereby it may be necessary to share data with the IPC, DVLA, IAS, credit reference agents, debt collection agents or solicitors.
Depending on the nature of your appeal, the information you may give may be classed as sensitive personal data. For example: if you give information relating to a medical condition you have, we will only use this information as part of your appeal and we will not use it for any other purpose. We will request your consent where we need to disclose this information to a third party, in order to verify your appeal.
By submitting your appeal, you consent to the use of that information as set out in this Privacy Statement.
Privacy Statement – Payment Page
This privacy statement has been produced in accordance to the Data Protection Act 1998 and applies to all personal data, as defined in the Act submitted when you click on the “Pay by Card” buttons from the National Parking Enforcement Website or via the Appeals Section.
Accepted Use of the Information
When using the pay by Card section, you accept that you will be redirected to the separately hosted web pages of either the Payment Processor for Card Payment provider.
For making an Online Payment: any personal data you supply via Payment Processor will be collected and processed by the Payment Processor only for the purposes outlined below. Such information may include: your parking charge reference, card number, expiry date and Security Code. The parking charge reference will be used for locating the relevant parking charge to enable the Payment Processor to populate the payment screen with the outstanding amount payable and the other details will be used by the Payment Processor to process the transaction. We will be supplied with the status of the parking charge, e.g. “paid”, and the parking charge reference to help us allocate the payment made.
National Parking Enforcement Ltd will only process information you supply whilst making payment of your Parking Charge, including your name, postal address and card details via the Payment Processor and will not be permitted access to this information, save for the status of the parking charge, e.g. “paid”, and the parking charge reference. This information is subject to confidentiality and will only be used for this purpose by the Payment Processor.
Disclosing Data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to the Police without the consent of the data subject.
Under these circumstances, National Parking Enforcement Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board of directors and from the company’s legal advisors where necessary.
Our CCTV Camera systems may be used for:
Managing car parks, in relation to identifying breaches by a driver who has parked on private land, outside of the contractual terms and conditions signposted within the area.
For the prevention and detection of criminal activity.
For the prevention of anti-social behaviour.
National Parking Enforcement Ltd employs CCTV operatives who are licenced by the Security Industry Authority. These operatives possess and display CCTV Public Space Surveillance Licences and operate from a secure CCTV operations room.
Our CCTV systems and the images or footage produced by it are controlled by National Parking Enforcement Ltd, we are responsible for how the system is used and for notifying the Information Commissioner about the CCTV system and its purpose (which is a legal requirement of the Data Protection Act 1998). National Parking Enforcement Ltd always considers the need for using CCTV and will always decide if it is required for the effective control and management of a car park, prevention and detection of crime and for protection and safety of customers, visitors, staff and residents. It will not be used for other purposes.
We conduct an annual review of our use of CCTV.
Under the Protection of Freedoms Act 2012 the processing of personal data captured by CCTV systems (including images identifying individuals) is governed by the Data Protection Act and the Information Commissioner’s Office (ICO) has issued a code of practice on compliance with legal obligations under that Act. The use of CCTV by National Parking Enforcement Ltd is covered by the Act, regardless of the number of cameras or how sophisticated the equipment is. Objectives and targets of this CCTV policy explains how National Parking Enforcement Ltd will operate its CCTV equipment and comply with the current legislation. National Parking Enforcement Ltd does not use the CCTV system for covert monitoring.
Maintenance of the CCTV system is maintained by Shield Security and other nominated sub contractors under an annual maintenance contract that includes periodic inspections.
The contractors are responsible for:
Ensuring National Parking Enforcement Ltd complies with its responsibilities in relation to guidance on the location of the cameras.
Ensuring the date and time reference are accurate.
Ensuring that suitable maintenance and servicing is undertaken to ensure that images are clear
Ensuring that cameras are protected from vandalism in order to ensure that they remain in working order. Identification In areas where CCTV is used National Parking Enforcement will ensure that there are prominent signs placed at both the entrance of the parking and CCTV zone and within the controlled or managed area.
The signs will:
Be clearly visible and readable.
Contain details of the organisation operating the scheme, the purpose for using CCTV and who to contact about the scheme.
Be an appropriate size depending on context.
Type of equipment
National Parking Enforcement’s standard CCTV cameras record visual images only and do not record sound.
The data controller has responsibility for the control of images and deciding how the CCTV system is used. National Parking Enforcement Ltd has notified the Information Commissioner’s Office of both the name of the data controller and the purpose for which the images are used. All operators and employees with access to images are aware of the procedures that need to be followed when accessing the recorded images. All operators are trained in their responsibilities under the CCTV Code of Practice and are licenced by the Security Industry Authority as CCTV Public Space operatives.
Access to recorded images is restricted to staff that need to have access in order to achieve the purpose of using the equipment. All access to the medium on which the images are recorded is documented. All employees are aware of the restrictions in relation to access to, and disclosure of, recorded images.
Recorded images will be stored in a way that ensures the integrity of the image and in a way that allows specific times and dates to be identified. Access to live images is restricted to the CCTV operator unless the monitor displays a scene which is in plain sight from the monitored location. Recorded images can only be viewed in a restricted area by approved staff. The recorded images are viewed only when there is suspected parking breach or criminal activity and not for routine monitoring of the general public. National Parking Enforcement Ltd reserves the right to use images captured on CCTV where there is suspected criminal activity. Images retained for evidential purposes will be retained in a locked area accessible by the system administrator only.
Where images are retained, the system administrator will ensure the reason for its retention is recorded, where it is kept, any use made of the images and finally when it is destroyed.
National Parking Enforcement Ltd ensures that images are not retained for longer than is necessary. Once the retention period has expired, the images are removed or erased. Disclosure of the recorded images to third parties can only be authorised by the data controller. Disclosure will only be granted:
If its release is fair to the individuals concerned.
If there is an overriding legal obligation (eg information access rights).
If it is consistent with the purpose for which the system was established.
Subject access requests
Individuals whose images are recorded have a right to view images of themselves and, unless they agree otherwise, to be provided with a copy of the images. If National Parking Enforcement Ltd receives a request under the Data Protection Act, it will comply with requests within 40 calendar days of receiving the request. National Parking Enforcement may charge an administration cost of £10 fee for the provision of a copy of the images. If National Parking Enforcement Ltd receives a request under the Freedom of Information Act it will comply with requests within 20 working days of receiving the request. As a general rule, if the viewer can identify any person other than, or in addition to, the person requesting access, it will be deemed personal data and its disclosure is unlikely as a Freedom of Information request. Those requesting access must provide enough detail to allow the operator to identify that they are the subject of the images, and for the operator to locate the images on the system. Requests for access should be addressed to the data controller.
Refusal to disclose images may be appropriate where its release is:
Likely to cause substantial and unwarranted damage to that individual.
To prevent automated decisions from being taken in relation to that individual.
Monitoring and evaluation
National Parking Enforcement Ltd undertakes regular audits to ensure that the use of CCTV continues to be justified. The audit includes a review of:
Its stated purpose.
The images recorded.
The efficacy of this policy will be reviewed annually by the National Parking Enforcement Ltd board of directors. If it is decided to change the way in which we use CCTV, we will inform the Information Commissioner within 28 days.