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Let us assume for the purposes of the following discussion that a VRN can constitute Personal Data (PD).

From the moment of entry until the ticket is printed AND the number is deleted from the ticket machine's memory, the VRN is PD by definition [I'll ignore confusion between singular and plural].

Exclusively as printed on the ticket, the VRN would appear not to be PD by definition.

When the ticket is photographed by a CEO the VRN likely becomes PD by definition once again.

So, for an offending vehicle, might the ticket be considered to be part of the 'processing' of the PD - e.g. as a temporary storage 'device'?

M

Sent from my iPad

On 21 Jan 2013, at 05:34, Paul Ticher <[log in to unmask]> wrote:

> But let's consider the situation posited by Simon where the car registration is printed on the ticket but not recorded by the machine.  Since the definition says that data is information which 'is being processed ...' the information would cease to be data once the machine spits the ticket out and erases its memory.  The registration on the ticket wouldn't be data (or personal).
> 
> 
> 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:
> www.paulticher.com/data-protection-services
> 
> 
> ----- Original Message ----- From: "Grimbaldus" <[log in to unmask]>
> To: <[log in to unmask]>
> Sent: Monday, January 21, 2013 3:51 AM
> Subject: Re: 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]> wro

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