PRIVACY POLICIES

 

WEBSITE USERS

 

WHY WE PROCESS YOUR DATA

This privacy notice is for website users.

In summary, we process personal data for the following purposes:

• respond to website enquiries
• undertake direct marketing
• improve website performance and marketing

TRANSFERRING PERSONAL DATA OVERSEAS

For us to perform the normal functions of our company and in providing you with services, your information will not be transferred outside of the EEA.

AUTOMATIC DECISION-MAKING AND ONLINE PROFILING

Through the use of some cookies on this website we may carry out automated processing and profiling.

HOW WE USE PERSONAL DATA

Where we process your personal information for legitimate interests this means that we assessed that we have a legitimate interest in the processing for the stated purpose, that the processing is necessary for this purpose, and we have not infringed upon your interests, rights or freedoms.

Purpose	Data processed	Use of data	Lawful basis for processing	Data sharing	Retention period
Product Development & Service	Name, organisation, email address, physical address and phone number.	Where you are not yet a client, to contact you by phone, email or post.	Consent	IT service providers	1 year
		Where you are a client, to contact you by phone, email or post.	Legitimate interest		1 year
To respond to customer enquiries via website contact form	Name, email address, physical address and phone number.	Where you are not yet a client, to contact you by phone, email or post.	Legitimate interest	IT service providers	1 year
		Where you are a client, to contact you by phone, email or post.	Legitimate interest		1 year
To improve website performance	Device usage, website behaviour	The understand better how a visitor navigates the website	Consent	IT service providers Google, HubSpot	1 year

INFORMATION SOURCES

We receive information about you provided by third parties enable cookies.

Data type	Source
Device usage, website behaviour, age, location, gender, interests	Google
Device usage, website behaviour, location, gender, interests	HubSpot
Device usage, website behaviour, location, gender, interests	Hotjar

YOUR RIGHTS

Right	Detail
Marketing – You have a right to object to direct marketing.	You have a right to object to processing of your personal information for direct marketing purposes.
Access – You have a right to request a copy of the personal information we hold about you.	You have the right to request access a copy of your personal data.
Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information.	If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information.
Erasure – You have a right to request that we delete your personal information.	You may request that we delete your personal information if you believe that: • we no longer need to process your information for the purposes for which it was provided; • we have requested your permission to process your personal information and you wish to withdraw your consent; • we are not using your information in a lawful manner; or • you have objected to your data being processed.
Restriction – You have a right to request us to restrict the processing of your personal information.	You may request us to restrict processing your personal information if you believe that: • any of the information that we hold about you is inaccurate; • we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or • we are not using your information in a lawful manner.
Objection – You have a right to object to the processing of your personal information.	You have a right to object to us processing your personal information, including the profiling of your information (and to request us to restrict processing). We may override this request where: • we determine that there is a compelling and legitimate grounds for the processing; • we need to process your information to investigate and protect us or others from legal claims.
Portability – You have a right to data portability.	You may request us to transfer to a third-party your data in a machine-readable format where the: • personal information was provided on the basis of consent; • processing is by automated means; and • processing is based on the fulfilment of a contractual obligation.
Withdraw consent – You have a right to withdraw your consent.	Where we rely on your consent to process your personal information for a particular purpose, you have a right to withdraw your consent at any time for that purpose.
Access – You have a right to request a copy of the personal information we hold about you.	To exercise this right please contact us at: Defence Systems trading as Park Watch, 49 Station Road, Polegate, BN26 6EA info@parkwatch.com
Lodge complaints – You have a right to lodge a complaint with the regulator.	If you have an issue concerning the processing of your information then please contact our Data Protection Officer using dpo@parkwatch.com We hope that we can address any concerns you may have, but you also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk

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MOTORISTS

 

1. WHY WE PROCESS YOUR DATA

This privacy notice is for drivers or registered keepers of vehicles that have used a parking site that Defence Systems trading as Park Watch manages.

In summary, we process personal data for the following purposes:

• To determine adherence with the parking site’s terms and conditions.
• To issue a windscreen ticket.
• To issue a notice to keeper or notice to driver by post.
• To process the payment of a Parking Charge Notice.
• To pursue payment of an unpaid Parking Charge Notice.

2. OBLIGATIONS TO PROVIDE US WITH CERTAIN INFORMATION

If you are the driver (but not the registered keeper) of a vehicle for which a Parking Charge was issued, then you may elect to transfer the liability for the Parking Charge from the keeper to you. In this situation we will require your name and address for the purpose of transferring the Parking Charge liability to you. If you do not provide the required information, then we will not be able to transfer the liability to you and the liability for the Parking Charge will remain with the vehicle’s registered keeper.

If you intend to pay a Parking Charge fee, then you will be required to provide us with your address and payment card details for us to process the payment. If you do not provide the required information, then we will not be able to process the payment. We do not retain payment card details.

3. COLLECTION OF DATA

On parking sites, we operate your vehicle’s details may be captured by one or more of the following methods:

• Mobile device (by warden, landowner/land occupier or a landowner/land occupier representative)
• Camera (Automatic Number Plate Recognition or CCTV)
• Warden operatives also operate body warn video equipment for safety and evidence purposes.

4. AUTOMATIC DECISION-MAKING AND ONLINE PROFILING

We do carry out automated processing of Vehicle Registration Marks at some of the sites that we manage through the use of cameras. Decisions about whether to issue a notice to keeper for a contravention of the terms and conditions is not purely made by automated means.

5. INFORMATION SOURCES

Where we did not issue a notice to a driver or where a Parking Charge remains unpaid after it is due then we will obtain the following information.

Table 1 – Information sources

Data type	Source
Registered vehicle keeper name and address	DVLA (Driver and Vehicle Licensing Agency)
Make and model details	Motor industry database
Vehicle Registration Number (VRN), PCN issue number, date and time of contravention, location of offence (first four digits of the post code only) and information from the DVLA in relation to MOT and excise duty of VRNs.	National Persistent Evader Database

6. HOW WE USE PERSONAL DATA

Table 2 – How we use personal data

Purpose	Data processed	Use of data	Lawful basis for processing	Data sharing	Retention period
To verify authorised users of a parking site	Vehicle registration number	To check a vehicle against a list of authorised vehicles for that parking site	Legitimate interests	IT service providers	One month
Body Worn Cameras (BWC) a deterrent against threatening behaviour/ criminal activity	BWC footage	BWC footage may be used in situations where verbal and physical abuse may occur.	Public Interest	Law enforcement agencies, prosecution agencies, legal representatives.	30 days unless required for evidential purposes which will be held until the conclusion of any criminal proceedings.
To issue a Parking Charge	Vehicle registration number, vehicle make and model, location of parking site, date and time of Parking Charge, photographic evidence of the contravention	To issue a Notice to Driver	Legitimate interests	IT service providers, DVLA	Two years from the Parking Charge date (if paid in full) or when cancelled
	Keeper/driver name and address, vehicle registration number, vehicle make and model, location of parking site, date and time of Parking Charge, photographic evidence of the contravention	To issue a Notice to Driver or Notice to Keeper or both	Legitimate interests	IT service providers, DVLA	Two years from the Parking Charge date (if paid in full) or when cancelled.
To issue a Parking Charge	CCTV Footage	To issue a Notice to Driver or Notice to Keeper or both	Legitimate interests	IT service providers, DVLA	Maximum of 30 days unless required for evidential purposes which will be held until the conclusion of any legal proceedings.
To handle driver and keeper enquiries and complaints	Name, Address, vehicle registration number, Parking Charge reference	To confirm the identity of the caller and discuss the enquiry/ complaint	Legitimate interests	IT service providers, DVLA	Two years from the Parking Charge date (if paid in full) or 6 years if unpaid
	Date, time, and photographic evidence of the contravention	To discuss the enquiry/complaint	Legitimate interests	IT service providers, DVLA	Two years from the Parking Charge date (if paid in full) or 6 years if unpaid
To take payment for a Parking Charge	Payment card details	To process a payment	Legitimate interests	Card payment processor	We do not retain payment information
To pursue an unpaid Parking Charge	Keeper/driver name and address, vehicle registration mark, vehicle make and model, location of parking site, date and time of Parking Charge, photographic evidence of the contravention	To instruct debt recovery agents or solicitors	Legitimate interests	IT service providers, DVLA, Debt Recovery Agents, Solicitors	The longer of one month following payment in full or 6 years from the Event Date if the Parking Charge remains open
To handle requests under the GDPR	Name, Address, vehicle registration mark, Parking Charge, other personal data relevant to the request	To facilitate a Data Protection related request	Legal obligation	IT service providers, DVLA, ICO	One year from the date of the request
To handle calls from the public	Name, Address, vehicle registration mark, other personal data relevant to the call	To facilitate any calls made to our office	Legal obligation	N/A	90 days from the date of the call

7. TRANSFERRING PERSONAL DATA OVERSEAS

For us to perform the normal functions of our company and in providing you with goods and services, in some instances where we need to send personal data outside the UK. We either transfer to a country that has been deemed “adequate” for personal data transfers by the UK government (such as one of the countries in the European Economic Area) or we put in place approved international data transfer contract clauses (such as the UK’s International Data Transfer Addendum to the EU Commission Standard Contractual Clauses).

8. YOUR RIGHTS

Table 3 – Your Rights

Right	Detail
Marketing – You have a right to object to direct marketing.	You have a right to object to processing of your personal information for direct marketing purposes. However we will not undertake direct marketing to you.
Access – You have a right to request a copy of the personal information we hold about you.	You have the right to request access a copy of your personal data. If we believe that your request is manifestly excessive we then may refuse your request.
Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information.	If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information.
Erasure – You have a right to request that we delete your personal information.	You may request that we delete your personal information if you believe that: • we no longer need to process your information for the purposes for which it was provided; • we have requested your permission to process your personal information and you wish to withdraw your consent; • we are not using your information in a lawful manner; or • you have objected to your data being processed. Note: as it is lawful for us to process your personal data in connection with a PCN, we will not delete such personal data prior to its scheduled deletion date, which is specified as the Retention Period above.
Restriction – You have a right to request us to restrict the processing of your personal information.	You may request us to restrict processing your personal information if you believe that: • any of the information that we hold about you is inaccurate; • we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or • we are not using your information in a lawful manner.
Objection – You have a right to object to the processing of your personal information.	You have a right to object to us processing your personal information, including the profiling of your information (and to request us to restrict processing). We may override this request where: • we determine that there is a compelling and legitimate grounds for the processing; • we need to process your information to investigate and protect us or others from legal claims. Note: as a contravention of parking terms and conditions allows us to pursue payment for a PCN, we have a compelling and legitimate basis for processing your personal data in connection with your PCN.
Portability – You have a right to data portability.	You may request us to transfer to a third-party your data in a machine-readable format where the: • personal information was provided on the basis of consent; • processing is by automated means; and • processing is based on the fulfilment of a contractual obligation.
Withdraw consent – You have a right to withdraw your consent.	Where we rely on your consent to process your personal information for a particular purpose, you have a right to withdraw your consent at any time for that purpose. Note: in processing your personal data in connection with a PCN we do not rely on your consent.
Exercising your rights – you may e-mail the following address to make your request	dpo@parkwatch.co.uk
Lodge complaints – You have a right to lodge a complaint with the regulator.	If you have an issue concerning the processing of your information then please contact our Data Protection Officer using dpo@parkwatch.co.uk We hope that we can address any concerns you may have, but you also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk

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PARKING PERMITS PRIVACY POLICY

This Privacy Policy provides information required under UK data protection laws. When ‘personal information’, ‘information’ or ‘data’ is referred to herein this has the same meaning as ‘personal data’, as defined under UK data protection laws.

The Permit issuer (Landowner)
Defence Systems trading as Park Watch is a car park management company, who manage parking on behalf of private landowners. When processing your personal information, Defence Systems trading as Park Watch is defined as the ‘processor” and the Permit Issuer (Landowner) is defined as the “controller”, as per data protection laws.

1. WHAT DATA DO WE COLLECT AND HOW DO WE COLLECT DATA?

We will collect and process all the information you and/or the landowner/leaseholder supply when using this service. The type of personal information collected
As/where appropriate the following personal information is collected/processed – Title/Name/Postal address/Email (mandatory and password)/Telephone number/Mobile number/Vehicle related documents (such as a V5 form, MOT certificate, and insurance documentation, the Vehicle Registration Mark (VRM), / Vehicle make and model/ Engine type/ Fuel capacity/ Colour of Vehicle/ Emissions data/Evidence from a care agency, GP or local authority.

2. THE REASON YOUR PERSONAL DATA IS COLLECTED

When using this service your personal information is collected, on behalf of the landowner (Permit Issuer) and processed by Defence Systems trading as Park Watch, as necessary, to facilitate the parking arrangements/agreement that you have with the landowner (Permit Issuer). Personal information is processed in the following scenarios:

• Submitting an application for a permit with a specific landowner / leaseholder
• Reviewing permit applications in line with the landowner / leaseholder’s criteria
• Assessing permit applications and the applicant’s eligibility for a permit
• Responding to permit applications (whether successful or otherwise)
• Where an application is successful, to enter into an agreement for a permit
• To manage and perform the terms of any such permit agreement
• Printing issued permits
• Renewing a permit
• Amending a previously issued permit
• Corresponding with applicants about permits
• Sending automated alerts and emails relating to the issue, management, maintenance, and renewal of parking permits as well as in the provision of technical support
• Recording the details of your permit to enable us to monitor the proper use of the car parking facilities within the car park(s) to which your permit relates.

We will also process data in pursuit of our, your, the landowner / leaseholder, legitimate interests, including corresponding with you and / or the landowner / leaseholder about your permit (as outlined above), registering your permit, and providing technical support (where required). This processing is necessary to enable the provision of an effective car park management service.

We will also process data in pursuit of our, your, the landowner / leaseholder, legitimate interests, including corresponding with you and / or the landowner / leaseholder about your permit (as outlined above), registering your permit, and providing technical support (where required). This processing is necessary to enable the provision of an effective car park management service.

3. LAWFUL BASIS

The lawful basis relied upon for processing your personal information is your consent. You are able to withdraw your consent at any time. You can do this by contacting the Landowner (Permit Issuer), though this may invalidate your ability to park.

4. INTERNATIONAL TRANSFERS

For us to perform the normal functions of our company and in providing you with goods and services, in some instances where we need to send personal data outside the UK. We either transfer to a country that has been deemed “adequate” for personal data transfers by the UK government (such as one of the countries in the European Economic Area) or we put in place approved international data transfer contract clauses (such as the UK’s International Data Transfer Addendum to the EU Commission Standard Contractual Clauses).

5. HOW YOUR PERSONAL INFORMATION IS STORED

Your information is securely stored in data hosting servers based in the UK.

6. AUTOMATED DECISION MAKING AND ONLINE PROFILING

Automated decision making is NOT used in the parking permit application process. Where applicable, criteria provided by the landowner (Permit Issuer) is applied to assess entitlement to a parking permit however, prior to any final decision being made all applications are manually reviewed prior to a final decision being made.

7. WHO IS DATA SHARED WITH?

In order to deliver the parking permit services data is shared with Defence Systems trading as Park Watch, who facilitate the parking permit assessment and issuance process. Defence Systems trading as Park Watch may share data with certain third-party organisations including authorised sub-contractors such as mail service providers, IT service providers and payment facilitation service providers.

8. PAYMENTS

A third-party Payment Card Industry (PCI) compliant payment gateway provider is used to facilitate payments for parking permits as/when they are applicable. The Permit Issuer (Landowner) and Defence Systems trading as Park Watch do not store payment card details.

9. HOW LONG IS PERSONAL INFORMATION STORED

Information supplied as part of your application, including documents uploaded or any relevant details from such documents will be retained as documented in the table below. You will not be asked for any more information than is required to assess your application and your data will not be kept any longer than it is needed.

Table 1 – E-Permits – How we use personal data

Purpose	Data processed	Use of data	Retention period
Applying for a permit (including the handling of queries or complaints).	Title/Name/Postal address/Email (mandatory and password)/Telephone number/Mobile number optional, blue badge holder. Additional information Vehicle related documents (such as a V5 form, MOT certificate, and insurance documentation), the Vehicle Registration Mark (VRM), / Vehicle make and model/ Engine type/ Fuel capacity/ Colour of Vehicle/ Emissions data	To assess applications	One year from the permit end date
Applying for a visitor permit and/or contractor permit (including the handling of queries or complaints).	Vehicle make and model/ Engine type/Fuel capacity/ Colour of Vehicle/Emissions data	To assess applications	One year from the permit end date
Applying for a Carer permit (including the handling of queries or complaints).	Evidence from a care agency, GP or local authority. Vehicle make and model/Engine type/ Fuel capacity/ Colour of Vehicle/Emissions data	To assess applications	One year from the permit end date
To take payment for a parking permit, where permits are chargeable.	Payment card details	To process a payment	Not retained
To handle subject access requests.	All of the above	To facilitate a Data Protection	One year from the date of the request
To handle calls from the public	Name, Address, vehicle registration mark, other personal data relevant to the call	To support any queries	90 days from the date of the call

10. SECURITY OF YOUR PERSONAL DATA

Defence Systems trading as Park Watch will implement security controls and practices to protect your personal data appropriate to its nature. Systems and processes are in place to provide security measures that will prevent your data from accidental loss, alteration, or disclosure. Access to your data is limited to only those staff members who have a need to do so in order to carry out their duties.

11. YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights including:

• Your right of access – You have the right to ask for copies of your personal information.
• Your right to rectification – You have the right to ask to rectify personal information you think is inaccurate. You also have the right to ask to complete information you think is incomplete.
• Your right to erasure – You have the right to ask to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability – You have the right to ask for the transfer of your personal information to another organisation, or to you, in certain circumstances.

Please contact the Landowner/Permit Issuer if you wish to exercise any of the above rights.

How to complain
If you have any concerns about the use of your personal information, you can make a complaint to the landowner/Permit Issuer. You can also complain to the ICO (Information Commissioner s Office) if you are unhappy with how your data has been used.

The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Changes to this privacy policy
Defence Systems trading as Park Watch keeps this privacy policy under regular review and places any updates on this webpage.

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MANAGE MY CAR PARK 

 

1. WHAT DATA DO WE COLLECT AND HOW TO WE COLLECT DATA?

We will collect the following data in order for you to apply for and operate as a self ticketer in the capacity of a Freeholder / Landlord / Leaseholder, Agent (on behalf of the Freeholder) or Manager (on behalf of the Freeholder).

Such data will be provided by you in your application and will include:
Full name; date of birth; home address; email address; phone number; details of unspent convictions, photographic identification documents for example passport, driving license, utility bills, mortgage statement, credit card statement, bank statement, criminal convictions, and if you choose to be paid as part of the service, your bank account and sort code details. Submitting photographic evidence of specific landowner / leaseholder ownership rights.

2. WHAT IS OUR PURPOSE AND LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA?

Our lawful basis for processing data is the Performance of a Contract.

3. HOW WE PROCESS YOUR DATA AND WHY WE PROCESS IT

When using this service, personal data is collected and processed as necessary, for the performance of the contract reached with the Landowner / leaseholder including:

• Processing an application made by you to become a self-ticketer.
• Referring the application data to the International Parking Community (IPC) for assessing the applicant’s eligibility. (For further information please see the IPC Privacy Policy).
• To perform contract agreed with the landowner / lease holder.
• Registering your approved application.
• We will also process data in pursuit of our, your, the landowner / leaseholder, legitimate interests, including corresponding with you and / or the landowner / leaseholder about your self-ticketing practices (if necessary).
• Provide technical support (where required).
• Pay monies due via BACS transfer (where applicable).

This processing is necessary to have an individual approved as a self-ticketer and to enable the enforcement of parking restrictions using photographic evidence of a potential parking contravention, includes the car park signage where drivers are notified of specific terms and conditions of the car park and GPS co-ordinates to demonstrate the location and accuracy of any potential enforcement. When using this service your data is collected and processed, as necessary, for the assessment and approval of an individual’s status as a self-ticketer.

4. PROCESSING OF SENSITIVE DATA

Where you disclose any “special category data” when submitting an application via this service, you explicitly consent to this information being processed as part of your application, such as when assessing your eligibility by the IPC and corresponding with you about your application (including in relation to renewals). This data will not be used for any other purpose.

We will continue to process any “special category” personal data provided by you, as specified above, unless we are notified that your consent to processing has been withdrawn. If you wish to withdraw your consent, please email: dpo@parkwatch.co.uk.

5. HOW LONG WILL WE RETAIN / STORE YOUR DATA FOR?

We may retain any information supplied as part of your application, (excluding unspent conviction data) including documents uploaded or any relevant details from such documents, for the duration of your application and the period of time you remain an approved (by the IPC) self ticketer, plus 90 days. However, we will not ask you for any more information than we need, and we do not keep your information for any longer than we need to.

6. AUTOMATIC DECISION-MAKING AND ONLINE PROFILING

We do carry out automated processing of Vehicle Registration Marks at some of the sites that we manage through the use of cameras. Decisions about whether to issue a notice to keeper for a contravention of the terms and conditions is not purely made by automated means.

7. TRANSFERRING PERSONAL DATA OVERSEAS

For us to perform the normal functions of our company and in providing you with goods and services, in some instances where we need to send personal data outside the UK. We either transfer to a country that has been deemed “adequate” for personal data transfers by the UK government (such as one of the countries in the European Economic Area) or we put in place approved international data transfer contract clauses (such as the UK’s International Data Transfer Addendum to the EU Commission Standard Contractual Clauses).

8. WHO DO WE SHARE DATA WITH?

In order for you to be a self-ticketer, we may need to share data with certain organisations. This could include any authorised sub-contractors, such as, IT service providers, regulatory bodies such as The International Parking Community (IPC) and Law Enforcement agencies (i.e., The Police and other security organisations as required in the detection and prevention of a crime).

9. WHAT ARE YOUR DATA PROTECTION RIGHTS?

You have:

• The right to be informed.
• The right to access.
• The right to rectification.
• The right to erasure (‘right to be forgotten’).
• The right to restriction of processing.
• The right to data portability.
• The right to object.
• The right not to be subject to automated decision making and profiling.
• The right to lodge a complaint with the supervisory authority for data protection issues – the Information Commissioner’s Office (ICO).

If you have an issue concerning the processing of your information, then please contact our Data Protection Officer at: dpo@parkwatch.co.uk.

We hope that we can address any concerns you may have, but you also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.

If you wish to make a complaint about the processing of your personal data by Defence Systems trading as Park Watch with regard to this service or if you feel that Defence Systems trading as Park Watch has not addressed your concern in a satisfactory manner, you can address a complaint to the ICO, via their website: www.ico.org.uk.

10. CHANGES TO THIS PRIVACY POLICY?

We will keep this privacy policy under regular review and place any updates on this webpage.