Automated License Plate Recognition (ALPR) Policy

 

At some California locations, data about parking usage is collected using automated license plate recognition (“ALPR”) technology to verify parking times and other parking and transit management related purposes. California Civil Code Section 1798.90.51 requires ALPR providers to implement a usage and privacy policy regarding the collection, use, maintenance, sharing, and dissemination of ALPR information. To the extent we operate an ALPR system in California:

 

• The purpose for using the ALPR system and collecting ALPR data is in connection with parking and transit management to track the entrance and exit of vehicles into and out of properties that we manage.

• We engage third party independent ALPR systems for use within the properties we manage. Our Chief Executive Officer, Chief Technology Officer, Director of Project Management, Audit & Compliance Director, General Manager, Operations Manager and the service technicians, customer support and operations management team members reporting to the aforementioned Managers, Directors and Officers may, under certain circumstances, be able to access ALPR information.

• All personnel with access to ALPR systems and data will receive training on the proper use and handling of such data to ensure compliance with applicable laws and customer privacy.

• We have taken reasonable steps according to industry standards to safeguard the information technology utilized in relation to the ALPR systems including the implementation of procedures to ensure that our systems are free from any components that would permit unauthorized access by a third party.

• We do not sell, share or transfer any ALPR information.

• Our Chief Technology Officer is responsible for the oversight and implementation of our ALPR compliance including ensuring the data collected and stored is accurate.

• Upon customer request to verify ALPR information in our possession, we will take reasonable measures to do so and to confirm such information and, if inaccurate, correct the ALPR information.

• ALPR information will be retained as long as required to confirm and verify the legitimacy of charges incurred for use of the parking facility unless a shorter time is required by applicable law. The information will be purged when no longer needed for these purposes.