At certain of our locations, we conduct vehicle inventories using License Plate Recognition (LPR) technology; that is, we collect and maintain images of vehicle registration plates and the characters they contain, which are converted into computer-readable data (LPR Data). This policy governs the LPR system operated by the company in order to ensure the privacy and integrity of LPR Data and it applies to our employees and affiliates who have access to or use our system.
LPR Data may be used and processed for the following purposes:
- To determine correct parking fees for lost ticket transactions;
- To identify and track abandoned vehicles;
- To verify vehicle counts;
- To respond to inquiries of law enforcement agencies; and
- To issue fee notices.
We do not process or make the LPR system or LPR Data available to individuals for personal, non-commercial purposes. Our LPR system is managed by LAZ Parking, in collaboration with the third-party LPR system provider, who is responsible for safeguarding the LPR Data, including its collection, use, security, integrity, dissemination, retention, monitoring, and destruction, as well as ensuring all employees are operating the LPR system within the parameters of the law and this policy. As part of these responsibilities, LAZ Parking shall ensure that only authorized employees in our respective operations, as well as supporting departments, have access to LPR Data for legitimate purposes, including to carry out the LPR purposes listed above. Categories of authorized employees include, but may not be limited to: Facility Managers, Portfolio Managers, Assistant Managers, Supervisors, Auditors, and IT Personnel. Prior to being provided access to LPR Data, and annually thereafter, employees are required to participate in training on the safeguards we have for protecting this information. In addition to implementing this training, the authorized LAZ Parking employee in charge of oversight of the respective parking facility, in collaboration with the third-party LPR system provider, shall direct the monitoring of the LPR system and LPR Data in a number of ways, including through antivirus and other applications, as well as periodic review of certain log files to ensure the security and integrity of the LPR Data.
- A written request received by us, which includes: the name of the entity and person requesting the ALPR Data and the reason for the request;
- Review of all requests by the authorized LAZ Parking employee in charge of oversight of the respective parking facility or his/her designee;
- Approval or denial of requests, along with communication of the determination to the requesting party.
LPR Data in the LPR system is periodically reviewed to determine if LPR Data needs to be removed from the LPR system and destroyed. Violations of this policy will include disciplinary action up to and including termination of employment.
We reserve the right to revise this policy at any point in the future and such changes, to the extent permitted by law, will be retroactively applicable to data collected prior to any revision of this policy.