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Every Thank You Earned.
ALPR Privacy Policy

PRIVACY POLICY REGARDING AUTOMATED LICENSE PLATE READERS (ALPRs)

Ace’s Privacy Policy as it relates to California Civil Code 1798.90.51 et seq. is as follows:


A. Purpose and Scope

The purpose of this privacy policy is to ensure that the collection, use, maintenance,
sharing and dissemination of ALPR information is consistent with respect for individuals’
privacy and civil liberties and to comply with the provisions of California Civil Code
Section 1798.90.51 et seq. This policy is available to members of the public, in writing,
upon request to Ace Parking.

B. Administration

At some Ace Parking Locations, nightly vehicle inventories are conducted using automated
license plate recognition technology. This data may be used for all or any of the following
purposes:

1. To determine correct parking fees for lost ticket transactions;
2. To identify and track abandoned vehicles;
3. To verify overnight vehicle counts;
4. To respond to inquiries of law enforcement agencies.

All access to, and retention of, ALPR data shall be managed by Chief Information Officer.
or his designee.

1. Ace’s Chief Information Officer or his designee shall be responsible for the
monitoring of the ALPR system accessed by Ace to ensure the security of the
information and compliance with applicable privacy laws. Ace’s Chief Information
Officer or his designee shall also be responsible for the correction of data errors of
which he becomes aware.

2. Ace’s Chief Information Officer or his designee shall ensure that only authorized
personnel with a legitimate business need shall be granted access to ALPR data.

3. Authorized personnel include:

a. Lot checkers – When conducting nightly vehicle inventories, it is necessary for lot checkers
to review and enter license plate information into the onboard computerized ALPR system.
Lot checkers must verify all images being recorded are accurate.

b. Office Coordinators – When assisting cashiers with lost ticket transactions, it is necessary for
office coordinators to retrieve the entry date for the vehicle by running the license plate
through the Parking Access and Revenue Control System (PARCS) in order to assist the cashier with charging the customer the
correct amount.

c. Supervisors – Supervisors cover for office coordinators and run reports on a regular basis in
order to flag possibly abandoned vehicles. Supervisors also use the inventory numbers to
calibrate the lot counts in PARCS on a nightly basis. Supervisors will also call in and request
vehicle location information from the office coordinator when assisting lost customers with
finding their vehicles.

d. Managers – Managers cover for supervisors and office coordinators. Additionally, managers
are responsible for handling inquiries made by law enforcement agencies.

e. Auditors – Auditors have access to all facets of the PARCS reporting portal. This is
necessary to ensure all revenues are being properly captured and recorded and that there is
no manipulation of the system. Specifically, auditors will confirm the correct parking fee was
assessed for all lost ticket transactions by reviewing the entry date first-hand in the PARCS.

f. Maintenance Technicians – HUB and SAS maintenance technicians provide service and
maintenance to the PARCS system and have access to all reports within the system.

All personnel with access undergo training on proper use and handling of ALPR data in order to
safeguard customer privacy and comply with applicable laws. shall be responsible for the
development and implementation of training requirements for all authorized personnel.

The Chief Information Officer or his designee will monitor querying activity via electronic logs
to ensure searches are tied to legitimate transactions and other aforementioned business
needs.

The sale and unauthorized dissemination of customer license plate information is strictly
prohibited by company policy. Violations will include disciplinary action up to and including
termination of employment. shall develop, implement and monitor the process for and
restrictions upon the sharing or transfer of ALPR information to other persons. The
process for sharing or transfer of ALPR information shall, at a minimum, include:

1. a written request is made for ALPR data which includes: the name of
the entity requesting information; the name of the person requesting; and
the intended purpose of obtaining the information;
2. the request is reviewed by The Chief Information Officer or his designee;
3. The approved request is retained on file;

The Chief Information Officer or his designee is responsible for ensuring all locations are
operating the ALPR system within the parameters of the law.

Nightly inventory personnel must review and verify all license plate information collected is
accurate before uploading it into the system.

License plate information collecting using the ALPR system will remain on file for a period of 180
days and shall be automatically purged from the ALPR system upon the expiration of this
period.

ALPR system audits shall be conducted on a regular basis.

View Ace Parking’s Privacy Policy