My gut feeling would be that a vehicle registration number on its own, in
the absence of any other data, would not pass the Durant test. What does it
tell you *about* an identifiable living individual - other than that a
vehicle of which they are the registered keeper was in a particular place at
a particular time?
Paul Ticher
0116 273 8191
www.paulticher.com
22 Stoughton Drive North, Leicester LE5 5UB
For continuous priority support on Data Protection, sign up to my support
service:
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----- Original Message -----
From: "Jaines, Amy" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Thursday, January 17, 2013 1:30 PM
Subject: Vehicle Registration Numbers - Personal Data or not??
Good afternoon,
I am currently in the process of investigating a complaint that our
Council is unfairly processing personal data by requiring members of the
public to input their vehicle registration number at the time of
purchasing a car park ticket. The rationale for this is to stop 'ticket
swapping'. A car parking ticket will only be considered valid if the
registration number printed on the ticket matches the vehicle that it is
displayed in.
My gut feeling is that in this instance the registration number is not
personal data as defined by the Act. It would be very difficult to
identify a specific individual that purchased a ticket from the
registration number alone.
I have had a look on the ICO website but nearly the all the information
I can find relating to vehicle registration numbers concerns Google
Streetview or ANPR systems, neither of which would apply to this
scenario as we are not capturing any images.
I know that many Council's now operate this kind of car parking system
and wondered if anyone else has dealt with a similar complaint and how
you have responded?
Many thanks,
Amy Jaines - Information Governance Officer
Information Management
East Lindsey District Council,
Room 158, Tedder Hall, Manby Park, Manby
Louth, Lincolnshire, LN11 8UP
Tel: 01507 613409 ext. 3409
E: [log in to unmask]
<mailto:[log in to unmask]>
Website: www.e-lindsey.gov.uk <http://www.e-lindsey.gov.uk/>
Facebook: www.e-lindsey.gov.uk/facebook
Twitter: www.e-lindsey.gov.uk/twitter
'Lincolnshire's Coastal District'
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