X Council issues Penalty Charge notice and instead of sending the registered keeper pictures taken of the vehicle justifying imposition of the PCN, they send a web site link where these may be accessed on line. The recipient of the PCN is required to use the unique PCN number and the and VRN to log on and view the pictures. They do this using wifi in an internet cafe and complain that the lack of ssl encryption means their personal log on details have passed insecurely over the internet and that inadequate technical measures are in place to comply with principle 7.
Do you think this complaint is valid and as PCNs are now civil rather than criminal offence would you agree this is personal rather than sensitive personal data and likely harm is likely to be minimal (unless registered keeper is supposed to have been somewhere else)?
Lynn Evans
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Grimbaldus
Sent: 18 January 2013 13:27
To: [log in to unmask]
Subject: Re: [data-protection] Vehicle Registration Numbers - Personal Data or not??
Personal Data does not cease to be Personal Data by reason of being in the public domain (unless inscribed on a headstone). In so far as the DPA is concerned, a difference arises in the harm that could occur as a consequence of (unauthorised) disclosure, and therefore the level of technical and organisational controls that should be applied.
In regard to their expenses claims, several to many Members of Parliament were insistent that the VRMs of their vehicles were Personal Data and must be redacted. To be sure, they also claimed a security component.
M
Sent from my iPad
On 18 Jan 2013, at 07:06, "Scourfield, Brenda" <[log in to unmask]> wrote:
> If you have received this email in error, please notify us by telephone on 01437 764551 and delete it from your computer immediately. Os ydych chi wedi derbyn yr e-bost hwn trwy gamgymeriad, byddwch cystal â rhoi gwybod inni trwy ffonio 01437 764551. Wedyn dylech ddileu’r e-bost ar unwaith oddi ar eich cyfrifiadur.
>
> I don't think a registration number on its own is personal data - even
> if it is HRH1 - it is in the public domain.
>
> -----Original Message-----
> From: This list is for those interested in Data Protection issues
> [mailto:[log in to unmask]] On Behalf Of SHQ - Gardiner,
> Lee
> Sent: 18 January 2013 11:37
> To: [log in to unmask]
> Subject: Re: [data-protection] Vehicle Registration Numbers - Personal
> Data or not??
>
> To add to Paul's point until such time as Authority X seeks to impose
> a penalty and takes steps to identify the vehicle owner through the
> DVLA they don't have the additional information to even ID the data subject.
> All they have is the reg number and a time/place for the vehicle.
>
> Once they have obtained the registered keeper information from the
> DVLA then you can argue more strongly its PD as you has information to
> ID the individual. This of course assumes the offending driver is the
> registered keeper. If the driver isn't the registered keeper then it
> still isn't the driver's PD but it is the registered keeper's.
>
> Regards
>
> Lee Gardiner
> Data Protection & Freedom of Information Officer
>
> Knowledge Management Team
> Lancashire Fire & Rescue Service
> Service Headquarters
> Garstang Road
> Fulwood
> Preston
> PR2 3LH
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