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Privacy Policy

ALPR Privacy Policy

PRIVACY POLICY REGARDING AUTOMATED LICENSE PLATE READERS (ALPRs)

ACE’s Privacy Policy as it relates to California Civil Code 1798.90.51 et seq. is as follows:

A. Purpose and Scope

The purpose of this privacy policy is to ensure that the collection, use, maintenance, sharing and dissemination of ALPR information is consistent with respect for individuals’ privacy and civil liberties and to comply with the provisions of California Civil Code Section 1798.90.51 et seq. This policy is available to members of the public, in writing upon request to ACE.

B. Administration

At some ACE Locations, nightly vehicle inventories are conducted using automated license plate recognition technology. This data may be used for all or any of the following purposes:

  1. To determine correct parking fees for lost ticket transactions;
  2. To identify and track abandoned vehicles;
  3. To verify overnight vehicle counts;
  4. To respond to inquiries of law enforcement agencies.

All access to, and retention of, ALPR data shall be managed by the Chief Information Officer. or his designee.

  1. ACE’s Chief Information Officer or his designee shall be responsible for the monitoring of the ALPR system accessed by ACE to ensure the security of the information and compliance with applicable privacy laws. ACE’s Chief Information Officer or his designee shall also be responsible for the correction of data errors of which he becomes aware.
  2. ACE’s Chief Information Officer or his designee shall ensure that only authorized personnel with a legitimate business need shall be granted access to ALPR data. 
  3. Authorized personnel include:
    1. 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.
    2. Office Coordinators – When assisting cashiers with lost ticket transactions, it is necessary for office coordinators to retrieve the entry date for the vehicle by running the license plate through the Parking Access and Revenue Control System (PARCS) in order to assist the cashier with charging the customer the correct amount.
    3. 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.
    4. Managers – Managers cover for supervisors and office coordinators. Additionally, managers are responsible for handling inquiries made by law enforcement agencies.
    5. 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.
    6. Maintenance Technicians – HUB and SAS maintenance technicians provide service and maintenance to the PARCS system and have access to all reports within the system.

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 Information Officer or his designee shall be responsible for the development and implementation of training requirements for all authorized personnel. 

The Chief Information Officer or his designee will monitor querying activity via electronic logs to ensure searches are tied to legitimate transactions and other aforementioned business needs.

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. The Chief Information Officer or his 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:

  1. 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;
  2. the request is reviewed by The Chief Information Officer or his designee;
  3. the approved request is retained on file;

The Chief Information Officer or his designee is responsible for ensuring all locations are operating the ALPR system within the parameters of the law.

Nightly inventory personnel must review and verify all license plate information collected is accurate before uploading it into the system.

License plate information collected using the ALPR system will remain on file for a period of 180 days 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.

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