BACKGROUND:
Local Car Park Management understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.localcarparkmanagement.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
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“Account”
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means an account required to access and/or use certain areas and features of Our Site;
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“Cookie”
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means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
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2. Information About Us
Our Site is owned and operated by Local Car Park Management, a car park management company registered in England under company number 14379954.
Registered address: 128 City Road, London, EC1V 2NX
Main trading address: 128 City Road, London, EC1V 2NX
Data Protection Officer: Karl Russell.
Email address: dataprotection@localcarparkmanagement.com.
Telephone number: 03455481716.
Postal Address: LCPM, Corespace, 64 Viewfield Road, Ayr, KA8 8HH..]
We are regulated by IPC.
We are a member of IPC.
3. What Does This Policy Cover?
This Privacy Policy applies to your use of Our Site & how we operate in car parks across the UK. This Privacy Policy explains in detail the policy we refer to on our signs post in every car park.
Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our or collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling.
i) For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. You can contact them on 0303 123 1113 or visit http://www.ico.org.uk for more information
6. What Data Do We Collect?
Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies):
- · Name;
- · Address;
- · Email address;
- · Telephone number;
- · Payment information;
7. How Do You Obtain & Process My Personal Data?
Under the GDPR, we must always have a lawful basis for obtaining & using personal data. This is because the data is necessary for our performance of a contract with you and because it is in our legitimate business interests to use it.
We can obtain your full name, full address, telephone number (if available) and email address (if available) from the following sources:
- · Parking attendants on sites – VRM and vehicle details
- · DVLA – registered keeper details
- · Vehicle hiring companies – driver details
- · Vehicle leasing companies – driver details
- · Vehicle keepers – driver details
All of above are permitted to providing information and must provide information in order to correctly enforce parking charges set in our terms & conditions of car park sites & signage.
Your personal data will be used for one or more of the following purposes:
- · VRM & vehicle details will be collected to prepare PCN & details of breach of the terms & conditions, images will also be gathered of your vehicle for evidence
- · To serve you a valid PCN to your registered address obtained from DVLA; this is our legal obligation to serve you the notice
- · To send you any payment receipts for any payments you make;
- · Issue you with reminder letters for any unpaid parking charges;
- · Communicating with you, for any enquiries, whether by phone, email or by post;
- · To provide you with any evidence we hold in regard to your PCN.
- · Processing your payment online
- · Instruct 3rd party debt recovery companies & solicitors to recover unpaid parking charges
We use the following automated system for carrying out certain kinds of decision-making. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.
- · The following automated decision-making method(s) may be used:
o We use our bespoke system to calculate regular timescales to process your PCN, whether to stop any recovery action if PCN paid, or to proceed to debt recovery or litigation.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- · We will retain your data for 6 years from the date it was processed to justify our process to DVLA, IPC and maybe HMRC if requested;
9. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
We do not process your data outside of the UK/
The security of your personal data is essential to us, and to protect your data, we take only the relevant information relating your PCN.
10. Do You Share My Personal Data?
We may share your personal data with other companies in our group for debt recovery services and litigation purposes.
We may sometimes contract with the following third parties to supply certain services. These may include payment processing, debt recovery, litigation, appeals decision making & for audit purposes. In some cases, those third parties may require access to some or all of your personal data that we hold.
Sharing data with IPC for auditing purposes
IPC audit is carried out every year and they may want to see paper trail during the audit process, to which we must present the data to the IPC officers to assess.
Sharing data with DVLA for auditing purposes
DVLA audit is carried out every two years with LCPM, DVLA officers want to see evidence of the PCN being issued correctly and in the correct time frame, for this will share VRM and provide evidence of correspondence, appeals etc
Sharing data with POPLA for assessing appeals
We must involve POPLA for any declined appeals, POPLA will want to assess the evidence including the VRMs, images, correspondence letters, emails and notes in order to assess the drivers appeal fairly, therefore this information must be shared
Sharing data with debt recovery companies to enforce a parking contract
Any unpaid parking charges will need to be referred to debt recovery companies, for this they will require keeper information, contact details and details of the PCN in order for the debt recovery company to recover unpaid charges.
Sharing data with solicitor for litigation purposes
Solicitor will also require data sharing such as the keeper details, address, PCN details and evidence we hold of the PCN, in order, to serve court notice and provide true evidence in court.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
11.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site or when we obtain your data from the sources mentioned above, you may be given options to restrict our use of your personal data.
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see part 14.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14. How Do You Use Cookies?
We use cookies on this website. A cookie is a text file sent by a web server to a web browser, and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We may send a cookie which may be stored on by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of this website, to improve the website’s usability and for marketing purposes. We may also use that information to recognise your computer when you visit our website, and to personalise our website for you. Our advertisers may also send you cookies.
Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.) This will, however, have a negative impact upon the usability of many websites, including this one.
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google's privacy policy is available at: http://www.google.com/privacypolicy.html.
15. How Do I Contact You?
To contact us anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Data Protection Officer; Shazad Razzaq):
Email address: dataprotection@localcarparkmanagement.com.
Telephone number: 03455481716.
Postal Address: LCPM, Corespace, 64 Viewfield Road, Ayr, KA8 8HH.
16. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.