How does NCP's PCN (Parking Charge Notice) process comply with the Data Protection Act 2018 (DPA)?
The purposes of our processing; Due to the fact that a PCN is an attempt to recoup lost revenue, for breaching our parking terms and conditions we don’t rely on your consent to process your personal information for PCNs. We process your information through another legal basis called legitimate interest. We rely on our legitimate business interest to access and use your personal information to issue PCNs and follow up letters.
The categories of personal data concerned; we gather and use the following information for PCNs, vehicle registration numbers, CCTV/ANPR images along with the vehicle keeper’s contact details (name and address)
The recipients or categories of recipient we disclose the personal data to; we’ll disclose your personal information to the DVLA for auditing purposes and to our relevant strategic suppliers who assist with the enforcement process. We cannot disclose the details of our strategic suppliers as this information is business sensitive and disclosing will compromise the business. All suppliers are members of an Accredited Trade Association (ATA) such as the British Parking Association or the International Parking Committee so this information is exempt from disclosure (as stated in the DPA).
We have a contractual agreement in place with the third parties and we only disclose the minimum information necessary for them to assist us in our objective (as stated in the purpose of our processing)
How long we retain the information; we keep PCN information for 3 years as we’re legally obligated to for taxing and accounting purposes. We also keep the information to help resolve any disputes should a legal claim arise. Any PCNs which have been cancelled or voided, will have the personal data that was obtained for the implementation removed from our systems within 60 days.
How individual’s DPA rights work in relation to, right to request rectification, erasure or restriction or to object to such processing; these qualifying rights are available to you but please note that these rights aren’t absolute and require assessment to see if you qualify. Each request will be reviewed and assessed by our Data Protection Officer and/or our Legal team to see if the requester’s right(s) supersedes our legal interest and legal obligation(s). All decisions will be made on a case by case basis.
You have the right to request a copy of the information that we hold on you, but this is again a qualifying right that will require an assessment.
How do we get your personal information; we gather information by searching the DVLA database for your vehicle registration number via our CCTV/ANPR cameras and handheld devices. The database feeds back to us the registered vehicle keeper’s details, which includes their name and address.
The existence of automated decision-making; Our ANPR processes are such that each time an ANPR camera flags a potential contravention (no payment/under payment), prior to issuing a PCN, each contravention is manually verified to ensure it is issued correctly, or to the best of our knowledge with the information we have at the time. .
How do we protect your data if it is transferred to a country outside of the EU; We don’t transfer personal data outside of the EU.