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Clean Air Zone Privacy Notice

The purpose of processing

In conjunction with the Joint Air Quality Unit (JAQU) we have processed your number plate “Vehicle Registration Mark” (VRM) using the City’s Automatic Number Plate Recognition (ANPR) system for the purpose of assessing whether you are liable to pay a charge for your vehicle when it entered the Bath Clean Air Zone (CAZ). For this purpose, the Council is the joint data controller with JAQU.

For further information regarding how JAQU processes your data please visit https://multiple-vehiclecheck-pay.drive-clean-air-zone.service.gov.uk/privacy_notice

We may further be required to process this information should your vehicle be subject to enforcement action for failure to pay a charge. B&NES is the sole data controller for this processing activity.

Data taken from the ANPR is also used for the purposes of traffic management by the Council. For this purpose the Council is the sole data controller.

Data subjects

The registered vehicle owners of any vehicle entering the CAZ.

Personal data

The Council and JAQU treat your VRM as personal data.
When the CAZ Central Service checks VRMs against the DVLA database, JAQU and the Council may use and share your:
• Name
• Surname
• Phone Number
• Email address
• Number plate ("vehicle registration mark")

How is it used?

To enable the Council to operate its CAZ, JAQU is delivering the CAZ Central Service, a digital service that allows the Council to:

• Determine whether a vehicle entering a CAZ is compliant with the CAZ Framework, and if the vehicle is not compliant, whether it is liable to be charged and, if so, how much: and
• Provide a first point of contact for the resolution of queries and to support assisted digital users.

The CAZ Central Service also allows individual motorists and fleet operators to pay for entry into the CAZ.

An email address will be requested from you to allow a payment transaction receipt to be sent by GOV.UK Notify. The Council will be sent confirmation of the payment including the vehicle number plate that has been paid for. The payment information in the CAZ Central Service is matched with the ANPR feed from local authorities to exchange payment status.

JAQU and the Council will be using the Council's automatic number plate recognition (ANPR) cameras covering the CAZ to record your VRM. Your number plate will also be collected if you use the vehicle checker ("Check if you'll be charged to drive in a Clean Air Zone") service accessible at: https://www.gov.uk/check-clean-air-zone-charge.

Should a charge not be paid within 7 days the Council will take enforcement action and issue a Penalty Charge Notice (PCN).

The data that is captured will also be used by the Council’s Traffic Management Team to determine the most efficient use of the road network and the avoidance, elimination or reduction of road congestion or other disruption to the movement of traffic on the road network.

Profiling and automated decision making

ANPR is an automated system and the checks carried out by JAQU are also automated. An indication that a vehicle may be subject to a charge is reviewed by a member of the Council’s support team.
You have the right to request that automated decision making be reviewed and replaced by non-automated means (i.e. decisions taken by one of our expert Council officers). To exercise this right please email data_protection@bathnes.gov.uk

GDPR condition relied upon for processing personal data:

Article 6.1 e - Exercise of official authority
This is based on the Controller’s responsibilities under The monitoring and identification of contraventions of Part III and Schedule 12 of the Transport Act 2000 and Parts 2 and 6 of The Road User Charging Schemes (Penalty Charges, Adjudication and Enforcement)(England) Regulations 2013 pertaining to Bath's Clean Air Zone Charging Order.

For the purposes of traffic management, the duties placed upon the data controller under section 16 and 17 of the Traffic Management Act 2004.

GDPR condition relied upon for processing special category data

Article 9.2 g - Substantial public interest

Sharing of personal data with external recipients

The data captured by the ANPR system will be shared with the DVLA for the purposes of vehicle identification and qualification. In the case of a penalty notice being issued information will be shared with enforcement agents working on behalf of the Council.

No data will be transferred outside of the EU.

How long is the personal data retained by the Council?

We will retain your details on the ANPR system for a period of 30 days in most circumstances or for up to 120 days in the event of a penalty being issued. Information held in relation to payments will be held for up to 7 years.

For the purposes of traffic management, we will retain details in relation to the vehicle only and will retain this for up to 3 months.

Questions or concerns?

Please email data_protection@bathnes.gov.uk 

Appeals to the Information Commissioner’s Office

If you are unhappy about the way we have treated your personal data, or feel we have not properly respected your data subject rights, you have the right to contact the Information Commissioner’s Office (ICO) and tell them about this.

You can also contact the ICO by phone on 0303 1231113.