More or less everything is data. DPA or not.
Simon.
From: Grimbaldus [mailto:[log in to unmask]]
Sent: 21 January 2013 03:51
To: Simon Howarth; [log in to unmask]
Subject: Re: [data-protection] Vehicle Registration Numbers - Personal Data or not??
The information is clearly 'data' per DPA, but questionably 'personal data'.
Storage is not a requirement of the definition, it is but one element of 'processing'.
M
Sent from my iPad
On 20 Jan 2013, at 05:09, Simon Howarth <[log in to unmask]> wrote:
I must say, I do much the same as Jim. I have also come across a machine where it asked you to enter the make of your car rather than your registration number.
Don’t we have to ask the question, what is the data being used for and where is it being stored (which leads to other uses)?
My understanding is that the machine does not store a registration. It merely prints what you enter on the ticket and does not retain any information relating to car registrations. This being the case, then I can’t see how the typing of the information to print on a ticket which is then displayed in the vehicle bearing that registration would be personal data? Once you get back to your car the ticket is yours, with the registration number on, and there is no record of your visit (unless you count the plethora of CCTV cameras that have probably monitored your every move whilst you moved from Debenhams to Boots to BHS and back).
Simon Howarth MSc. MBCS CITP
www.informationedge.co.uk <http://www.informationedge.co.uk/>
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of J.S.M.Whitaker
Sent: 17 January 2013 17:30
To: [log in to unmask]
Subject: Re: [data-protection] Vehicle Registration Numbers - Personal Data or not??
<off-topic>
Following the High Court decision which rejected a Council’s attempt to make these tickets non-transferable, I always put in REFUSED on these machines.
Jim
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Jaines, Amy
Sent: Thursday, January 17, 2013 1:30 PM
To: [log in to unmask]
Subject: [data-protection] 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: <mailto:[log in to unmask]> [log in to unmask]
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