PCH Property, LLC and CenterCal Properties, LLC (“Owner”) utilize automated license plate recognition (“ALPR”) technology at 2nd & PCH shopping center (the “Center”).
A. Purpose
ALPR information may be collected, accessed, and used to:
- Support parking operations and compliance activities;
- Supplement or replace paper parking tickets;
- Log the times at which a vehicle enters or exits the Center;
- Determine the parking fee;
- Supplement or replace proximity access cards and permit stickers to grant location entry to subscription parking permit holders; and
- Facilitate a more efficient and expedient location exit for vehicles.
In addition, pursuant to their own ALPR policies, authorized users and vendors may collect, access, and use ALPR information to:
- Correct parking fees for lost entry tickets;
- Identify and track down abandoned vehicles left at the Center;
- Verify the count of vehicles parked at the Center;
- Help customers locate their vehicles;
- Identify open parking spaces;
- Permit entry/exit to vehicles without need for interaction at the entry/exit gate;
- Respond to inquiries from law enforcement, legitimate third-party subpoenas or civil discovery obligations, or from other legitimate third parties;
- Respond to legitimate third-party subpoenas or civil discovery obligations;
- Respond to inquiries from other legitimate third parties;
- Issue fee, parking violation, or citation notices;
- Collect on an unpaid debt; and
- Generate internal operational metrics and statistical reports.
B. Access and Use of the ALPR System(s)
The following parties are authorized to collect, access, and use the ALPR system(s) or ALPR information:
- Senior General Manager, who manages Center operations, including the parking and the ALPR system(s).
- LAZ Parking (“LAZ”) Personnel, who are responsible for parking operations and enforcement, specifically:
- Facility Managers and their designee(s);
- Program Managers and their designee(s);
- Parking Manager(s) and Assistant Parking Managers;
- Parking Supervisors;
- Auditors;
- Information Technology (“IT”) Personnel;
- Bookkeepers; and
- TIBA LLC (“TIBA”) Personnel, specifically Technician(s), who provide technology support services for the ALPR system(s).
More information on LAZ’s ALPR policy can be found, as of the date of this posting, at https://www.lazparking.com/legal/license-plate-recognition.
All personnel with access to ALPR information undergo training on the operation and proper use of the ALPR system(s) prior to being provided access to the ALPR system(s). Training may also include annual refresher trainings that may cover education about applicable laws, how to operate the equipment, how to safeguard password information, and how to properly access the ALPR system(s).
C. System Monitoring
Owner, LAZ, and TIBA use administrative, operational, technical, and physical safeguards to protect the ALPR system(s) and ALPR data from unauthorized access, use, destruction, modification, or disclosure. These measures include username(s) and password(s) and multi-factor authentication for access, monitoring log-ins and queries, routine maintenance and periodic testing by ALPR system(s) vendors, and user training.
Additional measures by LAZ include:
- Administrative: Username and password-protected access to the ALPR system(s). The ALPR system(s) shall document in a separate log all information access by username, including the date and time of access, the data elements used to query the ALPR system(s), the organization or entity with whom the username is associated or affiliated with, what ALPR data was accessed, and the purpose for accessing the data. In addition, the database usage shall be monitored and audited. ALPR system vendors, including the LAZ Facility Manager or their designees, run periodic audits to ensure access to the ALPR information was made by authorized persons for authorized uses.
- Operational: Training authorized users on proper use and secure practices when using ALPR data and the ALPR system(s) and database and taking steps to ensure that others who are designated as authorized users to be given access to the ALPR system(s) and ALPR data follow the requirements of this policy and applicable law.
- Physical: All network equipment and servers containing sensitive data are maintained and accessed only by authorized personnel. This includes the secure storage of computers with access to the database.
- Technical: All information is encrypted to protect any personally identifiable information. The ALPR system(s) workstations and servers shall be updated with the latest security patches on a regular basis. Antivirus protection will be utilized, and log files will be periodically reviewed. The ALPR data shall be secured, encrypted, and backed up regularly.
D. Information Sharing
Owner and the authorized users identified above do not sell ALPR information. They do not share ALPR information except for the purposes stated above or as obligated by law, such as by search warrant or subpoena.
E. Official Custodian
The official custodian of the ALPR information is the LAZ Facility Manager. For additional information please contact the LAZ Facility Manager at ayu@lazparking.com.
F. Data Accuracy
ALRP operator: Cal. Civ. Code § 1798.90.51(b)(2)(F) (“A description of the reasonable measures that will be used to ensure the accuracy of ALPR information and correct data errors.”).
ALPR end-user: Cal. Civ. Code § 1987.90.53(b)(2)(F) (“A description of the reasonable measures that will be used to ensure the accuracy of ALPR information and correct data errors.”).
Collection of or access to ALPR data may be automated in some cases so the ALPR data and details of collection or access are included in the ALPR system(s) without review. Although infrequent, license plate translation may be incomplete or inaccurate and ALPR data may include inadvertently collected or accessed information. Accordingly, the LAZ Facility Manager or their designee shall take the appropriate measures to ensure accuracy, correct license plate translation errors when identified and see that any inadvertently collected or accessed information is removed from the system and/or not used for any purpose.
TIBA performs monthly preventative maintenance of the ALPR system(s) to ensure ALPR system(s) are operating properly, including camera configuration and calibration. In addition, LAZ performs daily audits to verify that the cameras are functioning correctly.
G. Data Retention
ALPR information is retained for a period of 60 days or 365 days and then automatically deleted by the system. If the ALPR system(s) are nearing maximum storage capacity, ALPR information may be deleted manually before the 365-day period. ALPR information may be stored for a longer period if increased by legal obligations. Examples of legal obligations include administrative or judicial proceedings, such as search warrants, subpoenas, and litigation. Any ALPR information retained as a result of legal obligations will be destroyed once the legal obligation to retain it ends.
LAZ stores ALPR information in transactional format for an indefinite time period in its business intelligence unit. LAZ does not store photographs of vehicles, but instead alpha numeric license plate information and accompanying date, time, and location fields.
H. Changes to this Policy
This ALPR Usage and Privacy Policy may be revised from time to time by Owner. Any changes to this policy will take effect upon posting.
