We are Park With Ease Ltd.
This policy has been produced in line with the General Data Protection Regulation 2016 and the Data Protection Act 2018.
Any changes to this policy will be posted on this webpage. This policy was last updated on 01/08/18.
This Policy explains:
- Why we process personal data
- What personal data we collect and process
- When and why we will share personal data
- How long we will keep personal data for
This policy also explains your rights as a data subject, including information about the right to access the information we hold about you. In certain circumstances, you also have the right to object to the processing of your data, to request that processing be restricted, or to request that we rectify or erase the data we hold about you. Further information is provided below.
Under data protection law, if you request that we action any of these rights, we must verify your identity before providing information to you. We must also provide you with an explanation if we do not agree with your request.
We look after your personal data by having security that is appropriate for its nature and the harm that might result from a breach of security. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Those with who we share data are also required to process your data in-line with contractual safeguards and data protection law requirements.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
How do we collect data?
Images of vehicles and VRMs are collected via ANPR cameras and/or attendants on-site. Where in operation VRM data may also be collected and processed via the payment and/or terminals systems.
If you have received a Parking Charge Notice and you are the registered keeper of the vehicle, as held by the relevant vehicle licensing agency, then your data has been provided by the Driver and Vehicle Licencing Agency (DVLA) or international equivalent.
If you submit an appeal or otherwise correspond with us, the data processed by us will be as provided by you within that appeal or correspondence. Where someone appeals or corresponds with us on your behalf, then the data processed will be as provided within the documentation we receive from them.
What if you provide sensitive data within an appeal or correspondence?
Depending upon the nature and content of your appeal or correspondence, the information or documentation provided may be classed as “special category” personal data and will therefore be considered to be more sensitive.
Examples include: personal identity numbers, financial account information, information about an individual’s racial or ethnic origin, sexual orientation, political opinions, religious, philosophical or other similar beliefs, or information about an individual’s physical or mental health.
The information on the reverse of the correspondence issued by us explains that we will process any special category data provided based upon your explicit disclosure of that information.
When submitting an appeal via the website, you will also be specifically asked to provide your consent to the processing of any “special category” personal data you explicitly disclose as part of an appeal.
We will continue to process any “special category” personal data provided by you, as specified above, unless we are notified that your consent to processing has been withdrawn.
You are free to change your mind at any time and withdraw your consent. The consequence might be that we will no longer be able to consider your circumstances in full when reviewing an appeal and when considering whether further action is appropriate should a Parking Charge remain open.
If you wish to withdraw your consent, please contact us using the details provided below.
How will we process your data and why do we process it?
When using Park with ease car parks, personal data is collected and processed for the purposes of:
- Ensuring you comply with the parking terms and conditions, as displayed on signage throughout each car park, and to enforce those terms and conditions where necessary.
- Issuing a Parking Charge Notice where the parking terms and conditions have been breached.
- Progressing any issued Parking Charge to closure or payment, which includes reviewing and responding to appeals (both internal and with THE IAS) and seeking payment of the Parking Charge amount. Recovery may include collections undertaken via the use of debt collection agents and/or legal action (where required).
- Providing car park management services, including the prevention and detection of crime, and data analytics.
Our lawful bases for processing data are Performance of a Contract and Legitimate Interests.
If you are the driver of a vehicle using a Park With Ease car park, your data is collected and processed as necessary for the performance of the parking contract. This includes ensuring you comply with the parking terms and conditions, as displayed on signage throughout each car park, and to enforce those terms and conditions where necessary.
Who do we share data with?
In order to enforce the parking contract where a breach has been identified and to support the legitimate interests explained above, we may share data with the following organisations:
- Vehicle licensing agencies, such as the DVLA or an international equivalent. This includes sharing data to obtain the contact name and address details of a vehicle’s registered keeper, as well as sharing for audit purposes.
- The police or other security organisations for the safety and security of car park users, and in order to prevent and detect crime.
- Vehicle hire and lease companies where they confirm that a vehicle was on hire or leased on the date that that vehicle was captured parked in breach of the parking terms and conditions.
- Other organisations such as mail service providers, business process outsourcers, credit reference agencies, collection agents, legal advisors, IT service providers, and payment service providers.
What data is processed when you pay a Parking Charge online?
This privacy statement applies to all personal data which is submitted within the online form:
- When you click on the “Pay” button within the website
When you select your preferred payment channel, one of the following provider routes will apply:
What data will be processed?
The data processed whilst you make payment of a Parking Charge may include a VRM, a parking charge reference, email address, card number, expiry date and security code. The VRM reference will be used for the purpose of locating the relevant parking charge to enable the MSP / MSA or PSP to populate the payment screen with the outstanding amount payable.
Personal data may be processed on the grounds of legitimate interests to allow payments to be made and may also be processed due to it being necessary for us to process the same under a contract between you and Park With Ease.
How long will we keep your data for?
There are certain reasons why we keep hold of some of your data. How long we keep your data for depends upon the type of data we hold and the purpose(s) for which it was collected and processed.
We will store your personal data for no longer than necessary to support the purposes explained above.
We retain the personal data we hold about you for up to 6 years from collection in order to respond to any concerns or claims that may arise in that time. This may be extended if related correspondence or claims are on-going, or where a county court judgment has been issued in Park With Ease’s favour and remains outstanding.
If you ask us to restrict the way we process your data, or no longer want to receive marketing information from us, we will retain relevant data on suppression lists. This means that we will keep just enough data about you available to ensure that we continue to comply with your reasonable request.
What are your rights as a data subject?
Data protection law gives you the following rights. For further information, including to make a request or ask a question about your rights, please contact our Privacy Team using the details provided below.
We will review each request we receive. Under data protection law we do not have to agree with your request but if we refuse your request, we will still contact you within one month to explain why.
To object to the processing of personal data.
In certain circumstances, individuals have the right to object to the processing of personal data. Any such objection must be based on your particular situation. We will review each request we receive and if we refuse your request, We will inform you of the reason why We have not taken action.
To access personal data.
Individuals have the right to request a copy of the data held about them. We are required to verify your identity before passing you information and We may contact you upon receipt of your request to clarify your request. We will be unable to process your request until we have all required information.
To be informed about the processing of personal data.
To request that the processing of personal data be restricted.
Individuals may have the right to request the restriction or suppression of personal data. This right will only apply in certain circumstances.
To request that personal data is corrected if it is inaccurate.
Individuals may request that inaccurate personal data is rectified, or completed if it is incomplete.
To ask that personal data be erased.
The right to erasure is also known as ‘the right to be forgotten’ and individuals can request that their personal data is erased. This right will only apply in certain circumstances.
To request to move, copy or transfer personal data (“Data Portability”).
The right to data portability allows individuals to move, copy or transfer personal data easily from one IT environment to another. This right will only apply in certain circumstances.
Rights relating to automated decision making, including profiling
Individuals have the right to be given information about such processing, request human intervention or challenge a decision. This right will only apply in certain circumstances.
How can you contact the Information Commissioner’s Office?
If you are concerned about our processing of your data or if you have a privacy related query not answered by this policy, please contact our Privacy Team using the contact details below. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO). For further information, please refer to the ICO website, www.ico.org.uk.
How can you contact Park With Ease if you have a privacy related query?