Privacy Policy

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(please see relevant statements below)

 

● Parking Control Management (UK) Ltd.  ●  Registered in England & Wales No. 4395994 ● Registered Office - The Courtyard, 1A Cranbourne Road, Slough, SL1 2XF ●

 Data Protection Officer – Annie Clark | Contact – info@pcm-uk.co.uk

Parking Control Management (UK) Ltd (hereafter referred to as ‘the operator’, ‘us’ or ‘we’) are committed to protecting personal data in line with relevant legislation and guidelines. It is recognised that the operator is a data controller as described under the Data Protection Act 1998, the General Data Protection Regulations 2018 and the Data Protection Act 2018. Therefore, the operator processes and stores personal data in relation to a number of purposes. 

The statements below outline how the operator may use and process personal data in relation to

  • The issue and enforcement of Parking Charge Notices, inclusive of PCNs served by post
  • The issue and enforcement of Parking Charge Notices issued with the use of Automatic Number Plate Recognition technology
  • The use of Body Worn Video by Parking Control Management (UK) Ltd’s parking operatives
  • The issue of parking permits and visitor scratch cards
  • Those who reside at a development managed by the operator but do not have entitlement to park and/or do not require a permit
  • Dispute resolution and legal action 

As a data subject, you have the right to request all personal data held regarding yourself and your vehicle through a Subject Access Request. This request must be made in writing either to the operator’s postal address or via email directly to the Data Protection Officer.  A Subject Access Request will be fulfilled upon receipt of proof of identity. The fulfilled request will be sent by Royal Mail first class post to the provided address and completed within one month of receipt.

 Please note that Subject Access Requests are free of charge, except if the request is manifestly unfounded or excessive, particularly if repetitive. The operator may refuse to comply with the request or charge a reasonable administration fee of £10.00. 

Please also contact us (either by post or email), with proof of identification and any relevant information such as reference numbers, if you:  

  • Object to your personal data being processed, and/or 
  • Believe the details we hold on you are incorrect and would like us to rectify this, and/or
  • Would like us to delete the data we hold on you, and/or
  • Would like to restrict how we process your data

Please note that you have the right to request the above, however, when we receive your requests we may object to your request if we do not agree with it. However, if you do make the request, we will tell you if the request has been granted or not. 

If you feel that your data has been processed unfairly or unlawfully, you may complain to the Information Commissioners Office (ICO) at www.ico.org.uk 

For further information on your rights as a data subject, please refer to the ICO (website as above) and the text of the General Data Protection Regulations 2018.

 

Privacy Notice for Users of Car Park(s) –
in relation to the issue and enforcement of Parking Charge Notices (PCNs), inclusive of PCNs served by post


 Entry into a car park managed by the operator may result in your personal data being obtained, retained and processed. Should one be issued a Parking Charge Notice, the data processed may be inclusive of (but not limited to): the vehicle registration mark; time and movements of the vehicle; postal address of the keeper and/or driver of the vehicle; photographs of you and your vehicle; and any other data that may be relevant to a dispute over the use of the car park.

 The purposes for which the data is processed is as follows:

  • To ensure compliance with your obligations under the contract entered into when you entered and remained on the land
  • For the legitimate purposes of pursing the driver and/or any other party in relation to these contractual obligations.
  • To protect our client’s rights as owners of private land and any rights users of the lands may be granted.

 Our lawful basis for processing this data is as outlined under the General Data Protection Regulations 2018, Chapter 2, Article 6, Clause 1, subsets (a), (b) and (f): 

1.     Contract – “processing is necessary for the performance of a contract with the data subject or take steps to enter into a contract” 

2.     Legitimate interests – “processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party…” 

3.     Consent – “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”

For the avoidance of doubt, the legitimate interests referred to above are the pursuance of unpaid parking charges/ related enforcement and the legitimate interests of our clients in the protection of their rights as landowners. 

Where there is a fee which is payable, we may seek personal details of the registered keeper from the Driver and Vehicle Licensing Agency (DVLA). Should the registered keeper not be the driver at the time of the contravention, the name and address of the driver may be sought from the keeper or hirer of the vehicle.  

In most circumstances, data will be retained for up to six years. In some scenarios, data may be held for longer than this time frame. For example, where there is an ongoing dispute which requires us to hold the data for longer than normal or where a court order has been made allowing us to pursue outstanding money after the expiration of six years. 

Enforcement of Parking Charge Notices may include the passing of personal data to third parties such as debt recovery companies, solicitors and high court enforcement bailiffs. This is in line with the lawful justifications under which the data was obtained.

Personal data may be provided willingly and freely by the data subject through the representations procedure. This includes names and addresses, but may include sensitive personal data such as health information for appeals based in mitigation. Data is retained, again, for the legitimate interests of the operator and the operator’s clients. 

Should you make representation against a Parking Charge Notice, the operator is bound to offer the use of an Alternate Disputer Resolution (ADR) scheme as part of our membership to the Accredited Trade Association, the International Parking Community (IPC) and Schedule 4 of the Protection of Freedoms Act 2012. Therefore, if your appeal is rejected, personal data will be passed to The Independent Appeals Service (IAS), in order to facilitate this right. 

The IAS are a certified ADR entity pursuant to the European Directive on Alternative Dispute Resolution (ADR) (2013/11/EU). The personal data passed to them in the first instance is limited solely to the Parking Charge Notice reference number, your vehicle registration mark and the date on which your appeal was rejected. For further details on how your personal data may be used during dispute resolution, please refer to the relevant notice below.  

The initial sharing of data to the IAS is in our legitimate interests – to comply with our membership agreement with the IPC, the KADOE Agreement with the DVLA and thus, the continued operation of our service.


 

Privacy Notice for Users of Car Park(s) –
in relation to the issue and enforcement of Parking Charge Notices (PCNs) issued with the use of Automatic Number Plate Recognition technology

 

Entry into a car park managed by the operator with Automatic Number Plate Recognition (ANPR) technology in place may result in your data being obtained, retained and processed.  

All entrants to the car park will have their vehicle registration mark and time of entry/exit recorded. Should this not amount to a contravention of the terms and conditions for the use of the land, such personal data will not be retained.  It should be noted that anonymisation processes may occur to retain the data for reporting purposes. However, no identifiable data will be held. 

Should one’s parking period result in being issued a Parking Charge Notice, the data processed may be inclusive of (but not limited to): the vehicle registration mark; time and movements of the vehicle; postal address of the keeper and/or driver of the vehicle; photographs of you and your vehicle; and any other data that may be relevant to a dispute over the use of the car park. 

Please refer to ‘Privacy Notice for Users of Car Park(s) – in relation to the issue and enforcement of Parking Charge Notices (PCNs), inclusive of PCNs served by post’ for full guidance on how your data may be used.

 

Privacy Notice for Users of Car Park(s) –
in relation to the use of Body Worn Video (BWV) by Parking Control Management (UK) Ltd’s parking operatives

 

Entry into a car park managed by the operator may result in your personal data being obtained, retained and processed. Should one approach and negatively engage with a representative of the operator (i.e. an enforcement operative), they may employ Body Worn Video (BWV) technology for their safety.  

The data processed may be inclusive of (but not limited to) identifiable images of oneself, your vehicle registration mark and any other information provided over the course of the recording. 

BWV may be engaged by a parking operative should an individual become aggressive, violent or excessively confrontational.  

The purposes for which this data is processed is as follows:

  • The safety and security of our parking operatives while carrying out work on behalf of the operator.
  • To act in evidence in any arising dispute over any incident occurring on site.

 Our lawful basis for processing data is as outlined under the General Data Protection Regulations 2018, Chapter 2, Article 6, Clause 1, subset (f): Legitimate interests – “processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party…” 

These legitimate interests are that which are described as the purposes for data processing above. 

In the interests of safety, personal data obtained through the use of BWV may be passed to third parties; namely, the authorities, solicitors and our clients.

 

Privacy Notice for Users of Car Park(s) –
in relation to the issue of parking permits and visitor scratch cards

 

Applying for a permit from the operator may result in your personal data being obtained, retained and processed. The data processed may be inclusive of (but not limited to) your name; current address; vehicle registration mark; copies of documentation such as utility bills, insurance documents, V5 log books, lease documents, tenancy agreements and driving licenses; credit/debit card details; telephone contact numbers; e-mail addresses. 

The purposes for which the data is processed is as follows;

  • To implement a permit system, thereby fulfilling and protecting rights of residents that may be granted under lease documents or tenancy agreements with regards to parking. That is to say, ensuring those with entitlement to park can gain access to said parking. 
  • To implement a permit and enforcement system, thereby fulfilling the contractual obligations of the operator to our client.
  • To protect our client’s rights as owners of private land.
  • To act as evidence in any arising dispute over permit issue or entitlement to park 

The operator processes this data lawfully and fairly, with the lawful basis being as described under relevant legislation:

1.     Legitimate interests - “processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party…” 

2.     Consent – “the data subject has given consent to the processing of his or her personal data for one or more specific purposes” 

The legitimate interests have been outlined as the purposes for processing this personal data. Data may be passed to our clients (i.e. landowners) as part of their legitimate interests and contractual rights. 

In most circumstances, data will be retained for up to six years. In some scenarios, data may be held for longer than this time frame. For example, where there is an ongoing dispute which requires us to hold the data for longer than normal or where a court order has been made allowing us to pursue outstanding money after the expiration of six years. 

Sensitive debit and credit card details are, in the vast majority of cases, not held longer than 24 hours. In the case of a declined payment, the card details may be retained for up to 5 days in which the operator will attempt to contact the card-holder to verify the recorded information.

 

Privacy Notice for Users of Car Park(s) -  
who reside at the development and do not have entitlement to park and/or do not require a permit

 

Residing on the development whereby the landowner has authorised the use of the operator’s services may result in your personal data being obtained, retained and processed. The amount of data held varies according to parking rights. 

Should you have a right to park and require a permit or have previously purchased a permit (within the last six years), please refer to ‘Privacy Notice for Users of Car Park(s) – in relation to the issue of parking permits and visitor scratch cards’ for further information on how your details may be stored and processed. 

Should you have no rights to park or do not require a permit, data held may be inclusive of – 

  • Your name & full postal address
  • Images of your property

 Your full postal address may be recorded and marked as having no parking rights or not requiring a permit. Your name and postal address are unlikely to be held on our systems in conjunction with one another and your name is unlikely to be retained at all. 

Images of your property may be retained as part of our scheme implementation procedure. Upon installation of signage, photographs are taken of the parking area. Additionally, if correspondence is hand delivered, video footage, recorded on a body camera, evidencing the hand delivery is retained. 

For full details on the legitimate interests and purposes of the implementation of an enforcement scheme, please refer to ‘Privacy Notice for Users of Car Park(s) – in relation to the issue of parking permits and visitor scratch cards’.

 

Privacy Notice for Users of Car Park(s) –
in relation to dispute resolution and legal action

 

By applying for a permit and/or parking on controlled land, your data may be obtained, retains and processed. Should a dispute arise, the operator reserves the right to utilise any and all evidence held that is pertinent to the matters at hand. 

The data processed may be inclusive of (but not limited to) the following – 

  • Vehicle registration marks of enforced vehicles
  • Time and movements of enforced vehicles
  • Name and address of the keeper and/or driver of enforced vehicles
  • Photographs of enforced vehicles and their drivers/passengers
  • Vehicle registration marks of residential vehicles
  • Name and address of residents
  • Permit allocation
  • Email address and other contact details
  • Copies of documents such as utility bills, insurance documents, V5 log books, lease documents, tenancy agreements, driving licenses
  • Payment information including transaction details

The primary purposes of processing such data is outlined in the relevant privacy notices. 

By way of further explanation, please note that data provided in the representations process or permit application procedure may be retained and used as evidence should a dispute arise over a related Parking Charge Notice. Accordingly, data may be shared with relevant Alternate Dispute Resolution schemes, solicitors, mediation services and/or courts.  

This data is obtained and processed fairly and lawfully. Any data provided is done with the full consent of the data subject. However, the retention of such data does not rely on any such consent. The lawful basis for the processing and retention of this data is justified under the General Data Protection Regulations 2018; specifically, with reference to Article 6, subset 1(f) – 

“processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party…” 

The legitimate interests pursued by the operator and the operator’s clients can be summarised as follows –

Implementing and providing the operator’s service as a parking management and enforcement operator. This service is in place to protect the interests of both those with parking rights and the owners of such private land. Enforcement may also be in place in the interests of health and safety and/or access issues.

The pursuance of contractual obligations entered and agreed to as a result of parking contrary to the outlined terms and conditions. That is to say, the enforcement of Parking Charge Notices for the interests above.  

In most circumstances, data will be retained for up to six years. In some scenarios, data may be held for longer than this time frame. For example, where there is an ongoing dispute which requires us to hold the data for longer than normal or where a court order has been made allowing us to pursue outstanding money after the expiration of six years.