Introduction
Welcome to City Permits Limited’s (“City Permits”) privacy policy.
City Permits respects your privacy and is committed to protecting your personal data.
This privacy policy will inform
you as to how we look after your personal data when you visit our website (regardless
of where you visit it from) and
tell you about your privacy rights and how the law protects you.
1. Important infortmation and who we are
Purpose of this privacy policy
We are City Permits, a car parking management company. This privacy policy aims to give you information on how City Permits collects your personal data through your use of our car parks, our patrols through our car parks and this website, including any data you may provide through this website when you submit an appeal or contact us.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
City Permits Limited may act as controller and processor and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: City Permits Limited
Email address: enquiries@citypermits.co.uk
Postal address: European House, 93 Wellington Road, Leeds, West Yorkshire, LS12 1DZ
Telephone number: 0113 457 4092
You have the right to make a complaint at any time to the Information Commissioner's
Office (ICO), the UK supervisory
authority for data protection issues (www.ico.org.uk). We would, however, appreciate
the chance to deal with your
concerns before you approach the ICO so please contact us in the first instance.
For further information regarding our complaints policy please click here.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and Vehicle Registration Mark (“VRM”).
- Contact Data includes postal address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. When appealing a PCN you may provide us with data which is classed as a special category of personal data. We will process any special category of data provided based on your explicit disclosure of that information.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Attendance at our car parks. We may collect data of images of vehicles using our car parks and the VRM. This may be collected via CCTV cameras on site and/or attendants on site.
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you contact us via our website or by telephone. If you are not the registered keeper of the vehicle in question your data has been provided by a third party who has confirmed that you were responsible for the vehicle on that date or that you were driving the vehicle on that date or that the vehicle was hired or leased to you on that date.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Details of the cookies on our website can be found under clause five.
-
Third parties or publicly available sources. We will receive personal
data about you from various third parties and public sources as set out below:
- If you fail to pay a Parking Charge Notice within the prescribed number of days we may obtain Identity and Contact Data from the Drivers and Vehicles and Licencing Agency based inside the EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To process car parking permits
- Performance of a contract whereby your data is collected and processed as necessary for the performance of the parking contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
5. Purposes for which we will use your personal data
When using a City Permits car park your personal data is collected for the purposes of:
- Ensuring users comply with the parking terms and conditions, as set out on the signage of each car park and to enforce those terms and conditions where necessary
- Issuing a PCN where the terms and conditions have been breached
- Continuing PCN cases until closure or payment which includes reviewing and responding to appeals. This may include the matter being referred to debt collection agents or to our legal representatives where required.
- Managing the car parks including the prevention and detection of crime.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
The cookies we use on our website are detailed below:-
_ga
Used to distinguish users. Expires after 2 years.
_gid
Used to distinguish users. Expires after 24 hours.
_gat
Used to throttle request rate. If Google Analytics is developed via Google Tag Manage
this cookie will be name _de_gtm_[propertyid]. Expires after 1 minute.
AMP_TOKEN
Contains a token that can be used to retrieve a Client ID from AMP Client ID Service.
Other possible values indicate opt-out, inflight request or error retrieving a Client
ID from AMP Client ID service. Expires within 1 year.
_gac_[property-id]
Contains campaign related information for the user. If you have linked your Google
Analytics and Google Ads account, Google Ads website conversion tags will read this
cookie unless you opt out. Expires after 90 days.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and
we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent,
in compliance with the above rules, where this is required or permitted by law.
6. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in above.
- External Third Parties as set out in the Glossary at clause 10.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we
may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may
use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or
accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need to know. They will only process your
personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.
9. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may
retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a
prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the
personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes through other means, and the applicable
legal, regulatory, tax, accounting or other requirements.
Information relating to PCNs are retained under Inland Revenue guidance for financial transactions and we have an
obligation to hold this data for 6 years.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
10. Your legal rights
You have certain rights in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a
copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate
data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no
good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data
where you have successfully exercised your right to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your personal data to comply with local law. Note, however,
that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified
to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party)
and there is something about your particular situation which makes you want to object to processing on this ground as
you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information
which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your
personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. This will only be applicable in certain circumstances.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you
the best service/product and the best and most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by law). You can obtain further information
about how we assess our legitimate interests against any potential impact on you in respect of specific activities by
contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you
are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal
obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- The Police or other security organisations for safety and security of car park users and for the detection and prevention of crime.
- Vehicle licencing agencies such as the DVLA, this includes sharing data to obtain the contact name and address details of the vehicles registered keeper, as well as sharing for audit purposes.
- Other car parking organisations such as the British Parking Association (BPA), the Parking on Private Land Appeals (POPLA) service for parking events in England and Wales, landowners, managing agents, tenants, and authorised sub-contractors such as mail service providers, business process outsourcers, credit reference agencies, collection agents, legal advisors, IT service providers and payment service providers.
- HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.