Our Commitment to Privacy 282 Group Ltd T/A Pure Parking
Who we are:
282 Group Ltd T/A Pure Parking is a company registered in England and Wales whose registered office is 40 Carter Street, Uttoxeter, Staffordshire, England, ST14 8EU (Company number 11860561). Our Data Protection Officer can be contacted by emailing DPO@pureparking.co.uk
What we do:
When you enter and remain and exit private land operated by us, we take photographs of the vehicle and registration by Automatic Number Plate Recognition ANPR & CCTV cameras. Parking attendants may take notes and images about your vehicle and your activity on the private land. The data gathered by cameras or parking attendants is needed to determine your compliance with the parking and payment terms of your contract with us.
Your personal data is being obtained, retained and processed, depending on the category of user you are of our site. We also use our cameras to detect and deter criminal activity.
Data Protection Act 1998
282 Group Ltd T/A Pure Parking is 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 Data Protection Act 1998
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):
- Legitimate interests – “processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party…”
- Consent – “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”
Therefore, the operator processes and stores personal data in relation to a number of purposes.
Your Legal Rights
Your rights under Data Protection Legislation are as follows:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Please note that you have the right to request the above, but under data protection law we must; confirm who you are before providing information and provide you with an explanation if we do not agree with your request so, if you do make the request we will tell you if the request has been granted or not.
Right of Access:
You have the right to submit a Subject Access Request and this can be done to our DPO by emailing email@example.com . We will need to confirm who you are and obtain proof of your identity before providing you with information we may hold about you.
Our Purpose and legal bases for Processing Your Personal Data:
- The purpose of processing your data is to enable effective parking management and ensure compliance with your contractual obligations having come onto and the vehicle having remained on the private land. There are also legitimate interests for us to do so in order to pursue anyone who may be liable to pay sums due, defend legal claims, protect the rights of a land owner and for business interests.
- We are entitled to:
- Pursue a motorist for an unpaid parking tariff
- Pursue a motorist for an unpaid parking charge
- Ensure safety and security and help deter/detect criminal activity.
The Categories of “Personal Data” we process:
Where there has been no breach of the parking contract:
As a compliant user of our privately managed land, the personal data we obtain is your registration number. We may capture images of the vehicle, occupants or bystanders. A full list of your Rights under data protection law are summarised above. Where your data is obtained it will be retained for 12 months, only in order to be able to cross reference registration numbers for discrepancies. Retaining this data in this way enables us to properly and fairly manage the private land which sometimes means cancelling Parking Charges. We then erase your registration and any other images from our records.
Applying for a permit
Applying for a permit from Pure Parking 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
Where there is a breach of the private land Terms and Conditions and a parking charge becomes due:
- A) Attendant, ANPR and CCTV Camera enforcement
Where there is a breach of the private land Terms and Conditions and a parking charge becomes due, we may request details of the registered keeper of the vehicle from the Driver and Vehicle Licensing Agency “DVLA” and other third parties (for example the registered keeper or hire companies where applicable) who may possess information which could assist in pursuance of the unpaid parking charge and resolving any disputes.
- B) Windscreen Parking Charge issued by a Parking Attendant
If you have received a Parking Charge Notice on your windscreen, at the point the notice is placed on your windscreen, we will have obtained your personal details, which could include images of your vehicle, occupants/bystanders and the vehicle registration number.
If you or a third party pay the Parking Charge Notice within 28 days, your personal details will not be retained for longer than 12 months. Where there is an unpaid parking charge for over 28 days, we may request personal details of the registered keeper of the vehicle from the Driver and Vehicle Licensing Agency “DVLA” and other third parties (for example the registered keeper or hire companies where applicable) who may possess information which could assist in resolving any dispute.
The personal details we may obtain from the DVLA for both Camera and Parking Attendant Windscreen Parking Charges include:
- The name and address of the registered keeper;
- The make, model and colour of the vehicle;
- Confirmation of the registration number;
- Any other information that we gather, in pursuance of the unpaid parking charge, including information that is shared by you with us.
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
Your data will be held for sufficient time to enable the outstanding parking charges to be settled by you or another person and resolve any dispute. We may also keep data to monitor persistent offenders. However, your data will not normally be held for longer than 6 years in such circumstances. In some circumstances your data may be held for longer than 6 years, examples of this are:
- When there is an ongoing dispute which requires us to hold the data for longer than 6 years.
- Where a court order has been made allowing us to pursue outstanding money after the expiration of 6 years.
- Where contractual or legal obligations specific to a particular site require us to and we will only keep data for longer if there is no other way of meeting those obligations.
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.
Your personal data may be shared with:
- a parking tariff payment facilitator
- an external software provider
- debt recovery companies
- credit reference agencies
- external mailing services provider
- Police and Security Services
- Solicitors and high court officers/bailiffs where necessary to ensure compliance with your obligations under the contract
- Parking Association for auditing purposes and to manage complaints
- Our clients to assess appeal
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at firstname.lastname@example.org
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number : 0303 123 1113
ICO website : https://www.ico.org.uk