We are Secure A Space Ltd, a private parking operator, and we are committed to protecting and respecting your personal data and privacy. This policy explains how we obtain, keep secure and use your personal data and our company values in relation to data protection, in line with the General Data Protection Regulation and Data Protection legislation.
Who we are and how to contact us?
The data controller is Secure A Space Ltd, registered in England and Wales: 9301673.
If you want to request more information about this subject you can contact us using the following details:
Write to us at: FAO: Privacy Officer, Office 1, Riverside, Fox’s Marina, Ipswich, IP2 8NJ.
Telephone: 01473 353383 and ask to speak to the Privacy Officer
Under the GDPR your rights are:
- To be informed – we will inform you of where to find this privacy notice and further information and be transparent about how we process your data
- Access – You are entitled to ask us what details we hold about you and why we hold them. Please make any requests in writing to: The Privacy Officer, Secure A Space Ltd, Office 1, Riverside, Fox’s Marina, Ipswich, IP2 8NJ. Or you can email us at firstname.lastname@example.org. In order to protect your information, we request that you provide evidence of your identity such as a photocopy (do not send the original document) of your current passport or driving license.
- Rectification – If you think the data we hold about you is incorrect or we do not have all the information you think we should have, you can request that we rectify this information
- Erasure – Also known as “the right to be forgotten”. You can request that we erase the data which we hold about you but this may only be possible once we have finished processing the data. We must provide an explanation if we disagree with your request.
- Restrict processing – You have the right to restrict us from processing your personal data in certain circumstances. In such cases it will still be stored securely
- Data portability – You have the right to obtain and reuse your personal data that you have provided to us where this may be applicable
- Object – You have the right to contact us and tell us why you think we should stop processing your data
- Rights in relation to automated decision making and profiling – We do not use automatic decision making or processing
When contacting us about any of the above requests we will contact you within one calendar month, from the point we have been able to prove your identity with the necessary copies of documentation. We will contact you either to confirm we have carried out your request or why we have not been able to or do not have to process your request. Rest assured we will still contact you within the time to explain why this is the case.
Why we collect data about you?
When parking at a site managed by us, we may capture your details including vehicle registration mark via Parking Attendants and, at some sites, CCTV cameras, in order to enforce parking terms and conditions. To determine where terms have not been complied with and to enforce the parking terms and conditions, your personal data may be collected, processed, shared and retained.
Our lawful basis for processing data are:
- Contract: The processing is necessary for the performance of a contract, or steps which we have been asked to take prior to entering into a contract
- Legitimate interests: The processing is necessary for the legitimate interests of our own company, the land owner or their agent who we work on behalf of, or for dealing with legal claims.
Data we may collect about you
We process Personal Data. We only obtain this information in order to carry out our contractual responsibilities to our clients/customers and to individuals who park at sites managed by us, to enforce parking terms and conditions.
Sources from which we may obtain data about you include:
- Our parking attendants patrolling our sites or from CCTV cameras installed
- Our clients, such as Land Owners or their appointed agents with whom we have a contract to work on behalf of
- We may request details from the DVLA, where we have reasonable cause to do so, via a third-party agent working on our behalf. Both parties are fully audited by the DVLA and you can view our agent’s contact details, as well as directions on how to view their Privacy Notice on any Notice to Keeper received.
- From communication between us such as telephone calls, emails and letters
- Through the use of our website, when providing information regarding your case or for an appeal
- From authorised third parties, appointed by you to deal with an appeal on your behalf
Categories of data we may collect, process, share and retain about you include:
- Vehicle registration, make and colour
- Duration of parking/observation times or entry/exit times at private sites we manage
- Photographic evidence of vehicles issued a Parking Charge Notice including windscreen contents and vehicle interior contents
- Video footage and/or photographic evidence of vehicles parked within sites we manage where CCTV is in operation for parking management purposes.
- Payment details through external payment provider
- Driver/Keeper details
- Name, address, telephone, parking charge details (including date, time, location, contravention reason and amount outstanding), photographic evidence, POPLA evidence from appellants, outcomes of POPLA appeals, comments or correspondence provided to us, any associated charges regarding same vehicle details.
During the appeal stage personal data provided may also include:
- Resident’s name, address, email address
- Witness’ name, address, email address
- Reasons for the appeal
- Proof of any mitigating circumstances
You may voluntarily give sensitive personal data to us via telephone, letters or emails. We will only use this personal data when dealing with a parking charge notice or for making reasonable adjustment regarding a parking issue. This is likely to be either during an appeal, with us or through the Independent Appeals Service (POPLA). We would only store such details securely and for as long as necessary. We would also only share such sensitive personal information with other necessary members of staff and our Debt Recovery agents, or when dealing with a legal claim via Solicitors and Courts.
What we do with the data collected from you?
- To sort contraventions from non-contraventions in parking terms and conditions
- To enforce parking terms and conditions and pursue a Parking Charge Notice
- To request any additional information to help with our decision-making process during your appeal
- To assess your reasons for parking and individually determine an outcome in cases of appeal
- To liaise with Land Owners or their appointed agent with regards to your parking rights in an appeal
- To process your appeal and contact you faster eg. providing your home address allows us to easily contact you should your IT provider block emails or the email address you provided was incorrect
- To avoid unnecessary Keeper details having to be requested from the DVLA during the appeals process (via a third-party agent)
- To provide any discount or additional time, or payment plan where suitable
- To provide information on how to make an independent appeal
- For debt collection purposes of outstanding payments
- For fraud/crime prevention
We may share information about you with:
- Data processors -third party services which supply or support our services. We have contracts in place with our data processors which means they cannot do anything with personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us and hold it securely, retaining it for only the period we instruct.
- Third party appeals assessors in cases of independent appeals made
- Our accredited trade association, for auditing purposes only or when the data subject has made a complaint to the third party concerned
- The land owner or their appointed agent in cases of appeal and only where this may be necessary and beneficial to the data subject
- With our third-party agents to obtain DVLA information only where necessary, debt collection agencies, solicitors or courts to recover unpaid debts/outstanding charges.
Data Retention Terms
Our data retention policy ensures that all personal data held is kept only as long as necessary. This may be determined on a case by case basis. Data collected will only be kept as long as necessary for the basis it was initially collected for and will not be subsequently retained for another purpose.
In general, any non-contravention data will not be held for a period longer than 3 months and contravention data will not be held for longer than 6 years unless there is still an ongoing legal case.
All information that we obtain about you, or you provide to us either by email or through our website, is stored on secure servers until no longer necessary. In addition, we seek to protect the privacy of your information at all times when sharing with authorised parties and hold agreements in place with our processors to ensure that they treat your data in a similar way. Any paper documents you may send will also be stored securely and when no longer necessary, all relevant files and documents will be securely deleted or destroyed.
Your personal information will not be communicated to non-connected third parties such as marketing or advertising companies.
For additional information regarding our data retention policy you can submit a written request using the contact details provided earlier in this policy.
You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the Information Commissioner’s Office. Details can be found at https://ico.org.uk
This document was last updated on 3rd December 2018.