Privacy Notice – Gibraltar Car Parks Limited
Gibraltar Car Parks Limited (GCPL) is the Data Controller and Gibraltar Parking Management Services Ltd is the Data Processor for the purposes of data protection legislation. We will only process your information where it is lawful to do so. The purpose of processing your data is to deal with Fixed Penalty Notices (FPNs), and appeals, to operate the processes for zones, estates and other permits, and to manage HMGOG's car parks and car parking functions.
If you have received a Fixed Penalty Notice (FPN) the lawful basis for processing your information is for a task carried out in the public interest and the exercise of official authority vested in Gibraltar Car Parks Limited by HMGOG via legislation.
If you apply for a residents parking permit or a car park rental, the lawful basis for processing your information for a task carried out in the public interest and the exercise of an official authority vested in Gibraltar Car Parks Limited by HMGOG via legislation. Where you fail to provide information to GCPL, we may be unable to process your parking permit or rental application.
Personal information
The categories of information GPMSL shall process on behalf of GCPL may include but is not limited to:
* Details of your vehicle such as vehicle registration number, vehicle make and model.
* Vehicle registered keeper details such as name and address from other HMGOG departments or hire/lease companies.
* Contact we have had with you, such as any correspondence via email and post.
* Images captured by the Parking Management Officers (PMOs)(which includes body worn camera footage), ANPR vehicles and CCTV cameras.
* Call recordings and notes/transcripts of telephone calls and visits made to GCPL.
* Some transaction information if you have paid for a parking service by credit or debit card.
* Contact details you have supplied such as email address, telephone number etc.
* Correspondence
GPMSL operates ANPR vehicle technology on behalf of GCPL to scan vehicle number plates of vehicles parked throughout Gibraltar, for the purposes of assisting Parking Management Officers with their duty to enforce appropriate parking management of demarcated parking zones.
GCPL do not collect any personal data relating to ethnicity, race, political opinion religious or philosophical beliefs, trade union membership, sexual orientation (‘special categories of personal data’) or criminal convictions except where that processing may authorised by law.
GCPL may need to share your information with our service providers. If this is needed you will be informed of this at the point of data collection.
Your personal information may be retained for a maximum of 7 years after closure of your matter or transaction. Data retention is kept to a minimum and only for as long as it it actively required for the purpose for which it was collected.
You have a legal right to request from GCPL access to and rectification or erasure of personal data or restriction of processing about you or to object to processing. You also have the right to portability of your data (where processing is based on consent, a contract or is carried out by automated means). Where processing is based on consent, you have the right to withdraw your consent at any time. GPMSL will only process your information for the purposes for which the information is collected. Neither GCPL nor GPMSL will not transfer your personal information outside of Gibraltar. Your personal data will not be subject to automated decision-making.
Privacy Notice - Use of Body Worn Video (BWV) Cameras by Parking Management Officers
Parking Management Officers play a vital part in keeping traffic flowing safely and the transport network at its most efficient for all motorists, as well as helping pedestrians get around safely. To help ensure the health, safety and welfare of our PMOs when patrolling both on and off street parking restrictions, GCPL have made the decision to equip our enforcement officers with Body Worn Video Cameras to reduce the risk of verbal and physical aggression towards them.
Cameras will only be activated when the PMO considers they are in a situation where they are, or feel they are likely to be, subjected to verbal or physical abuse. Recordings will not be made routinely, or to capture evidence of parking contraventions. Evidence from organisations who use the cameras supports the view that the use of Body Worn Cameras has a significant impact in reducing abuse and aggression.
Recordings will be deleted after 1 month unless retention is required as part of a subject access request (SAR), or an internal or police investigation, in which case the recording will be retained securely until the investigation or SAR is completed. No other data is retained.
Access to recordings is limited to authorised officers, and the police for law enforcement purposes.
Why have BWV Cameras been deployed?
Over the last few years GCPL has noted a significant increase in the number of incidents of both verbal and physical aggression towards our PMOs. This included verbal intimidation, threats of violence, intimidation and inciting hate against our officers via social media, and physical assaults. GPMSL has a responsibility for the Health, Safety and Welfare of its staff. Parking Management Officers already regularly undertake conflict management training to help equip them with the skills needed to effectively manage confrontational situations.
How will I know when recording is taking place?
The cameras are worn overtly on the outside of the Officer’s uniform, normally on the chest or shoulder, and a light on the camera will clearly show when recording is taking place.
Officers will advise the member of the public where possible that they have commenced recording when they first activate the device.
Recordings will not be made of general patrolling duties or to capture evidence of parking contraventions.
The devices will only be used in a public place.
Who can access these recordings?
Authorised GCPL and GPMSL Management will be able to view the recordings for PMO training and development purposes, to identify areas for improvement when dealing with conflict. Authorised GCPL and GPMSL Management will also be able to view the recordings to support an internal investigation.
Statutory Prosecution Agencies such as the police will be able to view the recordings for law enforcement purposes, and recorded data may be released to them for evidential purposes for example to support a prosecution
Data subjects (the person who has been recorded) can request to view the recording at GCPL's offices. Requests must be made via a subject access request.
Website Privacy Policy
Your privacy is important to us. It is the policy of Gibraltar Car Parks Ltd and Gibraltar Parking Management Services Ltd to respect your privacy regarding any information we may collect from you across our online presence, https://www.gibcarparks.com/, and other sites and apps we own and operate.
Website Information we collect
Log data
When you visit our website or apps, our servers may automatically log the standard data provided by your device. This data is considered “non-identifying information”, as it does not personally identify you on its own. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.
We may also collect data about the device you are using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
Personal information
We may ask for personal information, such as your:
- Name
- Phone/mobile number
- Home/Mailing address
This data is considered “identifying information”, as it can personally identify you. We only request personal information relevant to providing you with a service, and only use it to help provide or improve this service.
How we collect information
We collect information by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used. You are free to refuse our request for this information, with the understanding that we may be unable to provide you with some of your desired services without it.
Use of information
We may use a combination of identifying and non-identifying information to understand who our visitors are, how they use our services, and how we may improve their experience of our website in future. We do not disclose the specifics of this information publicly, but may share aggregated and anonymised versions of this information, for example, in website and customer usage trend reports.
We may use your personal details to contact you with updates about our website and services, along with other service content that we believe may be of interest to you. If you wish to opt out of receiving such content, you can follow the “unsubscribe” instructions provided alongside any non-personal correspondence from us.
Data processing and storage
The personal information we collect is stored and processed in Gibraltar, or where we or our partners, affiliates and third-party providers maintain facilities. We only transfer data across jurisdictions subject to data protection laws that reflect our commitment to protecting the privacy of our users.
We only retain personal information for as long as necessary to provide a service, or to improve our services in future. While we retain this data, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure, and cannot guarantee absolute data security.
If you request your personal information be deleted, or where your personal information becomes no longer relevant to our operations, we will erase it from our system within a reasonable timeframe.
Cookies
We use do not use cookies on our website.
Third-party access to information
We use third-party services for:
- Analytics tracking
- User authentication
These services may access our data solely for the purpose of performing specific tasks on our behalf. We do not share any personally identifying information with them without your explicit consent. We do not give them permission to disclose or use any of our data for any other purpose.
We may, from time to time, allow limited access to our data by external consultants and agencies for the purpose of analysis and service improvement. This access is only permitted for as long as necessary to perform a specific function. We only work with external agencies whose privacy policies align with ours.
We will refuse government and law enforcement requests for data if we believe a request is too broad or unrelated to its stated purpose. However, we may cooperate if we believe the requested information is necessary and appropriate to comply with legal process, to protect our own rights and property, to protect the safety of the public and any person, to prevent a crime, or to prevent what we reasonably believe to be illegal, legally actionable, or unethical activity.
We do not otherwise share or supply personal information to third parties. We do not sell or rent your personal information to marketers or third parties.
Limits of our policy
This privacy policy only covers Gibraltar Car Parks Ltd's own collecting and handling of data. We only work with partners, affiliates and third-party providers whose privacy policies align with ours, however we cannot accept responsibility or liability for their respective privacy practices.
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Changes to this policy
At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.
Your rights and responsibilities
As our user, you have the right to be informed about how your data is collected and used. You are entitled to know what data we collect about you, and how it is processed. You are entitled to correct and update any personal information about you, and to request this information be deleted. Where relevant you may amend or remove your account information at any time, using the tools provided in your account control panel.
You are entitled to restrict or object to our use of your data, while retaining the right to use your personal information for your own purposes. You have the right to opt out of data about you being used in decisions based solely on automated processing.
Mobile Application Privacy Policy
Gibraltar Car Parks Ltd ("The Data Controller") and Gibraltar Parking Management Services Ltd ("The Data Processor") take seriously the need to protect the privacy of users of its mobile application (App). This Privacy Policy describes how GCPL and GPMSL together with our affiliates (collectively we, our or us in this Privacy Policy) may collect, use, disclose, and hold information about an identifiable individual (Personal Information) as well as other business or technical data, in the course of operating the App and providing parking, payment and other services to users via the App.
This Privacy Policy also describes the purposes for which we may use, disclose or hold such Personal Information and other data.
What we collect
We may collect information during the course of your relationship with us, or during your use of our App. This includes the following:
We may collect location data from the device you are using to access the App, in order to enable us to provide parking and other services via the App. This may require you to enable or authorise location services via the permission system used by your mobile operating system. If you do not enable or authorise location services, the App may not be able to provide you with all of its features or services.
When you establish a user account or user profile with us we may collect personal details from you. This may include some or all of the following: your name, a user name, password and an email address.
Information about you or the vehicle you are parking may also be collected electronically at the parking location by our systems.
We may collect other Personal Information and data during the course or as a result of your relationship with us, including (without limitation) where necessary to enable us to provide products and services to you or to respond to requests for further information.
What we do with your data
We will use, disclose and hold Personal Information and data collected by us via the App in order to operate the App and to provide parking services via the App. This includes completing and processing sales transactions with App users and carpark providers, establishing and maintaining user records, providing technical support and administration services in relation to the App, and product development or research or evaluation.
We may also disclose and hold Personal Information and data collected by us via the App to the extent necessary to respond to your queries or requests for information or assistance, to provide after-sales service, or to keep you informed about products, services, events, promotions or any other marketing activities, but only to the extent permissible under applicable laws, and subject to any other restrictions contained in this Privacy Policy.
We may provide your Personal Information and other data to service providers and other third parties, but only to the extent reasonably necessary to achieve the purposes described in this Privacy Policy, or where we reasonably believe that such use or disclosure is required or expressly permitted under any applicable law.
Holding Personal Information
We will not hold your Personal Information for longer than is reasonably required for the purposes for which we may lawfully use that Personal Information.
Deleting your Personal Information
If you wish to have your Personal Information deleted from the Mobile Application systems, this is performed via the "Delete My Account" functionality which can be found under the "My Profile" option within the app. Once you have confirmed and completed the actions provided by "Delete My Account", your Personal Information as specified in your profile will be removed. Please note that this will remove all personalised access to the app functionality.
Statistical data that we collect
We may collect statistical data about your use of the App. This may include the date, time and length of your use or the pages or features of the App that you visit or use. We may also collect information about the device you are using to access the App. This information may be collected by software operating on our App, or by third party service providers on our behalf.
We may use and disclose such statistical data to maintain and optimise the technical performance, operation and security of the App, to identify user behaviour and user trends on the App, to measure the effectiveness of any services or features provided via the App, and to assist in resource planning.
We may disclose such statistical data to others for any purpose, but only on an aggregated basis and in a way that ensures that no individual is able to be identified from such data.
We may also use or disclose any of the data about users of the App that we collect for any purpose other than those purposes expressly permitted under this Privacy Policy, but only on an aggregated basis and in a way that ensures that no individual is able to be identified from such data.
Cookies
Our App may use cookies. "Cookies" are small text files that are placed on computers, devices or browsers used to access websites, apps or other internet content. We may use cookies to remember information about your personal preferences and user settings for the App, to analyse App traffic and trends, and to generally understand the behaviours and interests of people who use the App.
Our cookies will only use information about your personal preferences and user settings so that our App will remember your details next time you visit. We may use, disclose or sell other data collected by us from cookies for other purposes, but only on an aggregated basis and in a way that ensures that no individual is able to be identified from such information.
You may be able to change the settings on the device that you use to access the App in order to reject or limit the use of cookies, but this may reduce the functionality of the App.
Marketing
We may use Personal Information collected by us or via the App to send or email to you marketing or promotional information about our services or products, or the services or products of other companies (Direct Marketing Information), but only if you have expressly given us permission to do so.
If you have given us permission to send to you Direct Marketing Information, and you later decide that you do not want us to send you any further Direct Marketing Information, you can contact us at any time to request that we stop sending you such information. You can either contact our Privacy Officer (see the details at the end of this Privacy Policy) or use the "Unsubscribe" facility at the bottom of any Direct Marketing Information email or communication that we send you.
We will not sell your Personal Information to direct marketers unless you have expressly given us permission to do so.
Use of third-party websites
If you access any third-party websites via a link from the App, you will leave the App. By accessing these links you are not covered by the policies relating to the App. We are not responsible for the content of any third-party websites, or their use of your Personal Information.
Business acquisition
We may transfer your Personal Information to another entity in connection with a sale of our business or assets, a merger or consolidation or restructuring of our business or company, or any other transaction in which a third party acquires ownership of any rights in the App.
Transfer of Information
We may transfer the information described in this Privacy Policy to or from other countries to the extent necessary to enable us to operate the App and to provide services via the App. Some of these countries may have less protective privacy or data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your Personal Information in accordance with this Privacy Policy.
Security
We will use all reasonable endeavours to effect and maintain adequate security measures to safeguard the Personal Information we hold from loss or unauthorised access, use, modification or disclosure. However, as the internet is an open network, we do not warrant or guarantee that your Personal Information is safe from loss or unauthorised access, use, modification or disclosure, either during transmission to or from the App, or when held by us.
Contact
Feel free to contact us with a Subject Access Request or if you have any concerns or questions about how we handle your data and personal information.
Gibraltar Car Parks Ltd
Data Protection Officer Email: dpo at gibcarparks.com
Telephone: 200 49202Gibraltar Parking Management Services Ltd
General Enquiries Email: operations at gpmsl.gi
Telephone 200 64622This policy has been updated and is effective as of 19th September 2022
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