Privacy policy regarding license plate reading cameras (LPRs)

AirGarage’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 LPR 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 AirGarage.

B. Administration

At some AirGarage Locations, 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 time-based parking sessions;
2. To identify and track abandoned vehicles;
3. To verify vehicle counts;
4. To respond to inquiries of law enforcement agencies.

All access to, and retention of, LPR data shall be managed by the Chief Technology Officer or his designee.

1. AirGarage’s Chief Technology Officer or his designee shall be responsible for the monitoring of the LPR system accessed by AirGarage to ensure the security of the information and compliance with applicable privacy laws. AirGarage’s Chief Technology Officer or his designee shall also be responsible for the correction of data errors of which he becomes aware.
2. AirGarage’s Chief Technology Officer or his designee shall ensure that only authorized personnel with a legitimate business need shall be granted access to LPR data.
3. Authorized personnel include:
   1. Lot Enforcers – When auditing location occupancy, it is necessary for lot enforcers to review and enter license plate information into the LPR system. Lot enforcers must verify all images being recorded are accurate.
   2. AirGarage Employees – Employees run reports on a regular basis in order to flag unpaid or possibly abandoned vehicles. Employees also use the inventory numbers to determine location occupancy levels. Additionally, Employees are responsible for handling inquiries made by law enforcement agencies.
   3. Maintenance Technicians – Camera maintenance technicians provide service and maintenance to the LPR system and have access to all reports within the system.

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. The process for sharing or transfer of LPR information shall, at a minimum, include:

1. a written request is made for LPR 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 Technology Officer or his designee;
3. the approved request is retained on file;

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