Privacy Notice

Who We Are

We are Athena ANPR Ltd and are registered in England and Wales (05678510).

Our registered office address is at 3 Acorn Business Centre, Northarbour Road, Portsmouth. PO6 3TH.

We are a car park management company that operates ANPR or CCTV controlled car park sites on private land.

We are the data controller in respect of all personal information that we process in connection with our business.

General Privacy Information

At Athena we take privacy seriously, respect your right to privacy and protect any personal information we collect.

This privacy notice explains, how and why we collect, use store and share personal information in connection with our business. It is designed to tell you everything you need to know about how we treat your personal information.

"Personal information" means information about a living individual who can be identified from that information (either by itself or when it is combined with other information).

We keep this Privacy Notice under review. Any updates will be published on our website.

How To Contact Us

If you have any queries or would like more information please contact our Data Protection Officer at:

dpo@athena-parking.com

or by calling 0330 403 0123

or by writing to, Data Protection Officer, Athena ANPR Ltd, PO BOX 4758, ASCOT, SL5 5DJ.

Our Lawful Basis For Processing Your Personal Information

We have two lawful bases for processing your personal information:

  1. Because the processing is necessary for the contract with us which was created when you entered and remained on the car park
  2. For these legitimate interests, which are proportionate to your rights and freedoms:
    1. To pursue motorists for unpaid parking tariffs;
    2. To pursue motorists for unpaid parking charges;
    3. To ensure safety and security and help deter/detect crimes;
    4. Providing car park management services on private land, including the management of permits and the adjudication of appeals both ourselves and on behalf of our clients;
    5. As part of the audit processes undertaken by the DVLA and the industry regulator, the International Parking Community (IPC);

What Personal Information Do We Collect And How Do We Collect It?

We use an ANPR or automatic number plate recognition system. Images of vehicles and the Vehicle Registration Mark (VRM) are collected via ANPR cameras. We automatically record an image of the number plate (VRM) of every car that enters and exits the car park, as well as the time that happens and we record an image of the vehicle at a distance.

VRM, date, time and location data may also be collected and processed via terminal registration systems if they are in operation. Where this happens we will tell you clearly through onsite signage.

Where we issue a parking charge or tariff, then we collect more information. We obtain the name and address of the registered keeper of the vehicle from the DVLA.

If you are not the registered keeper of the vehicle, then we have obtained your data from the registered keeper or from another person that the registered keeper has referred us to, who has identified you as the driver/hirer of the vehicle on the time and date of the parking event.

If you submit an appeal or otherwise correspond with us, then we will process the personal information that you give to us. Where someone appeals or corresponds with us on your behalf, then we will process the personal data we receive from them. If you appeal, we will usually process information about your status as driver, if you are the registered keeper of the vehicle or the hirer/lessee or other relationship with the vehicle, your name, postal address, email address and telephone number, the details of the appeal and any evidence submitted to us.

Special Category or "Sensitive" Data

We will only collect special category personal data when you provide it to us via correspondence or if you appeal against a charge or tariff. Examples of this kind of data include: information about an individual's racial or ethnic origin, sexual orientation, political opinions, religious, philosophical or other similar beliefs, or information about an individual's physical or mental health.

We will use, store or share this special category of data only in two circumstances:

  • If you have given your explicit consent, or
  • The processing is necessary for the establishment, exercise or defence of a legal claim.

What Data Is Processed When You Pay A Parking Charge Online?

If you use our website to pay a parking charge, we will process the Parking Charge Notice (PCN) number and VRM that you submit. We will process your email address and/or postal address if you provide them so we can send you a receipt for your payment.

We use SagePay as our PSP (payment service provider) to process your payments via our web site. SagePay is a PCI DSS Level 1 compliant vendor. When you make a payment you will be submitting your card details to the SagePay system. We do not store your payment card information.

What Data Is Processed When You Pay A Parking Charge Using Our Automated Telephone Service?

If you use our automated telephone service (on 0330 223 1888) to pay a parking charge, we will process the PCN number you submit to allow you to hear details of your parking charge, this will include your VRM. We will process your telephone number if you provide one so that we can send you a receipt for your payment via text message. We do not store your payment card information.

Our automated telephone service is PCI DSS Level 1 compliant.

We use SagePay as our PSP (payment service provider) to process your payments via our automated telephone payments line. SagePay is a PCI DSS Level 1 compliant vendor. When you make a payment you will be submitting your card details to the SagePay system. We do not store your payment card information.

Why Do We Collect Your Personal Information

We manage ANPR or CCTV controlled car park sites on Private Land. The sites are privately owned and operated and so we need your personal information to confirm entry and exit of the car park, to calculate the length of stay and to determine whether you should be charged for parking and to collect any charges. We also need your personal information when we are managing, administrating and processing appeals against parking charges or tariffs.

We also need the personal data to ensure safety and security and to help deter or detect crimes.

Our Data Retention Policy

We always retain information in accordance with legal requirements. We only retain the data necessary in order to fulfil those requirements.

Where your vehicle registration number has been recorded on our systems but has complied fully with the terms and conditions of the site, your data is deleted within 48 hours, or if a bank holiday intervenes, then after the bank holiday.

Where there is an unpaid charge the data will be held for sufficient time to enable the charge to be settled by you, or another person, to resolve any dispute and to satisfy any statutory obligations. We will hold your records for 2 years after your case has been considered as we are required to comply with regulatory and legislative requirements.

We are required to keep accounting details for 6 years in accordance with HMRC rules.

In accordance with PCI DSS regulations we do not store payment card details for payments made or attempted.

If there is an order from a court or there is an investigation by law enforcement agencies or our regulators, we may be required to retain your information beyond the retention period set out above. This is intended to make sure that we will be able to produce records as evidence, if they are needed.

How We Share Your Personal Data

We keep your information confidential and will not share it without your prior consent, other than to the following:

  • the Independent Appeals Service (IAS), the independent adjudicator for private parking appeals, when you are involved in an appeal;
  • the Driver and Vehicle Licensing Agency (DVLA);
  • to the IPC, the industry regulator, when responding to a query or a complaint made in relation to a parking charge or event that they are assessing;
  • debt recovery agents, if you fail to pay a charge or tariff;
  • bailiffs or solicitors if recovery is required or legal action is taken;
  • the freeholder of the car park or the client on whose behalf we are providing parking facilities, to confirm information the landowner may already have because an appeal, claim or complaint has been made or you have entered into correspondence with them;
  • or to other service providers, such as Payment Service Providers or IT System Providers as our authorised sub-contractors.

No information collected by us is used for any marketing purposes. We do not sell or pass information to others for marketing purposes.

How We Protect Your Data

We look after your personal data by having security that is appropriate for its nature and the harm that might result from any breach of security.

Our organisation is accredited to the ISO 9001 standard for Quality Management and ISO 27001 standard for Information Security. We are Cyber Secure Accredited.

Your Privacy Rights

We want to make sure you are aware of your rights in relation to the personal information we process about you.

You have the following rights: the right of access; the right of rectification; the right of erasure; the right to restriction of processing; the right to objection; the right to portability; the right to not be subject to automated processing and the right to be informed.

Access

You have a right to request a copy of any of your personal information that we hold, as well as to ask us for details about how we process your personal information. If your request is unclear we will contact you and ask you to clarify your request. If we are unsure about your identity we will ask you for more information and will only begin to process your request once your identity has been verified.

You can make a subject access request by contacting our Data Protection Officer at: dpo@athena-parking.com or by calling 0330 403 0123.

Rectification

You have the right to ask us to rectify or delete any of your personal information that is inaccurate as to any matter of fact, or if your personal information is incomplete.

Erasure

The right to erasure is also known as 'the right to be forgotten'. You can request that we erase all of your personal information when it is no longer necessary for us to continue processing this data and in some other limited circumstances, as described in the Information Commissioner's guidance, available on www.ico.org.uk

Restriction

You have the right to request the restriction or suppression of your personal information. This right will only apply in certain circumstances, as described in the Information Commissioner's guidance, available on www.ico.org.uk.

Objection

In certain circumstances, you have the right to object to the processing of your personal information. Any such objection must be based on your particular situation. We will review each request we receive and if we refuse your request we will inform you of the reason why we have not taken action.

Portability

You have the right to receive personal data you have provided to us in a structured, commonly used and machine readable format. You also have the right to request that we transmit this data directly to another organisation.

Automated Decision Making

You have the right to not be subject to any decision based on automatic decision making. This right will only apply in certain circumstances, as described in the Information Commissioner's guidance, available on www.ico.org.uk. We do not carry out Automated Decision Making.

Informed

You have the right to be informed about how we collect and use your personal data. We comply with your right through this privacy policy, and by telling you key information about data collection on the signage located on all sites we manage.

International Transfers

We do not transfer data internationally. Your data will not be transferred anywhere outside of the EEA.

How To Contact Us

Our Data Protection Officer can be contacted at:

dpo@athena-parking.com

or by calling 0330 403 0123

or by writing to, Data Protection Officer, Athena ANPR Ltd, PO BOX 4758, ASCOT, SL5 5DJ.

How To Contact The Information Commissioners Office (ICO)

Information about the General Data Protection Regulations is available within the Information Commissioner's guidance, available at www.ico.org.uk.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO). For further information, please refer to the ICO website, www.ico.org.uk.

Press Privacy Statement

Once a media request is submitted, we will only process the data you have supplied to us.

The data we will process may include the following:

  • Name
  • Email Address
  • Phone Number
  • Job Title
  • The content of the enquiry

It is within our legitimate interest to process this data for the purpose of reviewing and responding to the incoming enquiry.

We may share this data with our clients to confirm information provided but will not share this data with any other third party without your prior consent.

Recruitment Privacy Statement

If you apply for a job position with us and send us a copy of your CV, we will only process the data you have supplied to us.

The data we will process may include the following:

  • Contact Details
  • Any other information contained within the CV
  • Any other information contained within a covering letter / email

It is within our legitimate interest to process this data for the purpose of managing the recruitment process.

We will not share your data with any third parties without your prior consent.

Supplier Privacy Statement

This notice is provided for our prospective, existing and former suppliers and their staff (referred to in this notice as "You" and "Your").

We collect, hold and use the following types of data about you:

  • Publicly available information about you, such as your business contact details and information.
  • Data including; name, address, email address, company registration number, company VAT number, account details, contact number, position within the company.

We use this information for the following purposes:

  • To manage and facilitate the provision of products and/or services by you to us;
  • To respond to any enquiry or feedback we receive from you;
  • Training purposes;
  • Compliance with legal requirements; and
  • To contact you about placing orders.

We will not share your data with any third parties without your prior consent.