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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

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:

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

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.

NO2 Plan Evaluation data
In order to understand the extent to which the programme is meeting its stated aim of reducing nitrogen dioxide concentrations to within legal limits in the shortest possible time, a clear understanding of fleet composition (with reference to Euro Standards) before, during and after implementation of Local Plan measures, is needed.

We will be sharing VRM details with JAQU quarterly for the duration of the evaluation. DfT will match this data with vehicle type and emissions data which will be anonymised, before being sent back to the local authority and 3rd parties (Ricardo Energy and Environment and Ipsos MORI) for further evaluation and reporting.

Local authorities and JAQU won’t retain the VRM data, but DfT will retain pseudonymised data (where identifying details are replaced with a key) for no longer than 12 months.

The Joint Controllers have agreed the following arrangement to determine their respective obligations under the UK GDPR:
• They have jointly prepared this privacy notice.
• They will cooperate with each other in responding to any request each receives from data subjects exercising their rights under data protection legislation in relation to their personal data (a ‘Data Subject Request’). The party which receives the Data Subject Request will fulfil the obligations of the controller to respond to the request in accordance with data protection legislation.
• They will provide reasonable assistance to each other to enable a Data Subject Request to be dealt with in an expeditious and compliant manner.
• Each shall be responsible for fulfilling the controller’s responsibilities under data protection legislation as to security of personal data when that personal data is processed on systems controlled by that party.
• If one Joint Controller discovers a data breach, that party (the ‘Reporting party’) will be responsible for assessing whether the breach constitutes a personal data breach that is required to be notified to the Information Commissioner’s Office and (where applicable) to the data subjects under Articles 33 and 34 of the UK GDPR. The Reporting party shall fulfil the obligations of the controller to give such notice, if it is required, in accordance with data protection legislation.
• They have agreed to provide reasonable assistance to each other in order to facilitate the handling of any data breach in an expeditious and compliant manner.
• In the event of a dispute brought by a data subject or a data protection authority concerning the processing of personal data against either or both of them, the Joint Controllers will inform each other about any such disputes or claims, and will cooperate with a view to settling them amicably in a timely fashion.

Irrespective of the above arrangement, you can exercise your rights under the UK GDPR in respect of and against each of the Joint Controllers if you wish.

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 

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.