Privacy Policy

Overview

We are Combined Parking Solutions Limited, a car park management company.

When collecting the data specified in this privacy policy, we are the Data Controller.

Combined Parking Solutions Limited is registered with the Information Commissioners Office under registration Z3310983.

Any changes to this policy will be posted on this webpage. This policy was last updated on 25th May 2018.

This Policy explains:

* Why we process personal data;
* What personal data we collect and process;
* When and why we will share personal data;
* How long we will keep personal data for; and

This policy also explains your rights as a data subject, including information about the right to access the information we hold about you. In certain circumstances, you also have the right to object to the processing of your data, to request that processing be restricted, or to request that we rectify or erase the data we hold about you. Further information is provided below.

Under data protection law, if you request that we action any of these rights, we must verify your identity before providing information to you.
We must also provide you with an explanation if we do not agree with your request.

Data Security

We (Combined Parking Solutions Limited) receive personal information through this website. You may, for example, be asked for personal information if you want to take advantage of specific services that we offer, such as ordering online or subscribing to our publications.
Where you provide personal information, we will only use it to deliver the services you have requested.

With regard to each of your visits to our site, we may automatically collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL) click-stream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. The information which we collect and store during normal use of the site is used to monitor and analyse how parts of the site are used.

Cookies

Cookies collect anonymous information about how visitors use our site, which is then used to help improve the site. The information collected includes the number of site visitors, where visitors come to the site from and the pages they visited.

Google Analytics
We use Google Analytics, a web analytics service provided by Google. Google Analytics uses ‘cookies’, which are text files placed on your computer, to help analyse how visitors use combinedparkingsolutions.com.

Cookie name What is it
_utma Typical content: randomly generated number
Expires: 2 years
_utmb
Typical content: randomly generated number
Expires: 30 minutes
_utmz Typical content: randomly generated number and information about how the page was reached (eg directly or via a link, organic search or paid search)
Expires: 6 months

For further details on Google Analytics cookies, including those not used by combinedparkingsolutions.com, visit cookies set by Google Analytics.

Content Management System cookies
Used by the software (Vignette) which displays our website content to remember selections or preferences you’ve already made.

Cookie name What is it
VignettePortal-NavTreeState-cps Typical content: randomly generated number
Expires: when user exits browser

JSESSIONID Typical content: randomly generated number
Expires: when user exits browser
cookiesToolbar Typical content: randomly generated number
Expires: 90 days

General
You can choose to refuse cookies or tell your browser to let you know each time that a website tries to set a cookie. However, refusing cookies may mean some sections of the site will not work properly.

For more information about cookies (including how to turn them off) please visit www.allaboutcookies.org.

The type of data we collect

When you use any carpark managed by Combined Parking Solutions Limited we will collect and process data comprising of images of the vehicle including their Vehicle Registration Number.

If a vehicle is parked in a manner to which free parking is not permitted (ie, if you park in a location to which a valid CPS permit is required to be on display and you do not have one) then a Parking Charge Notice can be issued (PCN)

If you submit an appeal in relation to a Parking Charge, or otherwise correspond with us, including on the phone, you may provide us with additional personal data, the data we process may include: the VRM; your name, address, email and phone number; a Parking Charge or other reference number; the capacity in which you are appealing (e.g. keeper, driver, hirer, other); and any other information you provide within any correspondence, phone call or appeal, including any documentation you share with us.

How we collect that data

Images of vehicles and VRMs are collected via ANPR cameras and/or attendants on-site. Where in operation VRM data may also be collected and processed via the payment and/or terminals systems.

If you have received a Parking Charge Notice and you are the registered keeper of the vehicle, as held by the relevant vehicle licensing agency, then your data has been provided by the Driver and Vehicle Licencing Agency (DVLA) or international equivalent.

If you are not the registered keeper of the vehicle, then your data has been provided by:

* A third party who has confirmed that you were responsible for the vehicle on that date;
* A third party who has confirmed that you were driving the vehicle on that date;
* A third party who has confirmed that the vehicle was on hire or leased to you on that date.

If you submit an appeal or otherwise correspond with us, the data processed by us will be as provided by you within that appeal or correspondence. Where someone appeals or corresponds with us on your behalf, then the data processed will be as provided within the documentation we receive from them.

Sensitive Data

Depending upon the nature and content of your appeal or correspondence, the information or documentation provided may be classed as “special category” personal data and will therefore be considered to be more sensitive.

Examples include: personal identity numbers, financial account information, 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 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.

You are free to change your mind at any time and withdraw your consent. The consequence might be that we will no longer be able to consider your circumstances in full when reviewing an appeal and when considering whether further action is appropriate should a Parking Charge remain open.

How we process data and why we process it

When using a car park managed by Combined Parking Solutions Limited, personal data is collected and processed for the purposes of:

Ensuring you comply with the parking terms and conditions, as displayed on signage throughout each car park, and to enforce those terms and conditions where necessary.

Issuing a Parking Charge Notice where the vehicle is not parked in a manner to benefit from free parking as per the terms and conditions displayed and the driver by parking has consented to a parking charge being issued.

Progressing any issued Parking Charge to closure or payment, which includes reviewing and responding to appeals (both internal and with IAS) and seeking payment of the Parking Charge amount. Recovery may include collections undertaken via the use of debt collection agents and/or legal action (where required).

Providing car park management services, including the prevention and detection of crime, and data analytics.

Our lawful bases for processing data are Performance of a Contract and Legitimate Interests.

If you are the driver of a vehicle using a car park managed by Combined Parking Solutions, your data is collected and processed as necessary for the performance of the parking contract. This includes ensuring you comply with the parking terms and conditions, as displayed on signage throughout each car park, and to enforce those terms and conditions where necessary.

We will also process data in pursuit of our, the landowners, and the public’s legitimate interests including:

The enforcement of the parking terms and conditions where the recipient of the Parking Charge was not the driver of the vehicle. Enforcement of the parking terms and conditions ensures a better overall parking experience for all users of the facilities.

The provision of an effective appeals service, which is provided in line with the IPC Code of Practice. Where the Parking Charge was issued in England and Wales, this includes an opportunity for all motorists to lodge an appeal with the Independent Appeals service should their appeal to us be rejected. Progressing the Parking Charges we issue, either to closure or payment, supports the parking services we offer.

The provision of an effective car park management service to improve the customer experience.

Sharing information with the landowner where they have agreed to provide parking permits to certain individuals (e.g. staff parking permits), or where a payment account for specified vehicles has been agreed.

Providing data to the police to assist with the prevention and detection of crime (as appropriate).

As part of the audit processes undertaken by the DVLA and the IPC.

Data may be processed at a destination outside the European Economic Area but we have implemented and ensured the safeguards required by data protection law.

Who do we share data with

In order to enforce the parking contract where a breach has been identified and to support the legitimate interests explained above, we may share data with the following organisations:

Vehicle licensing agencies, such as the DVLA or an international equivalent. This includes sharing data to obtain the contact name and address details of a vehicle’s registered keeper, as well as sharing for audit purposes.

The police or other security organisations for the safety and security of car park users, and in order to prevent and detect crime.

Vehicle hire and lease companies where they confirm that a vehicle was on hire or leased on the date that that vehicle was captured parked in breach of the parking terms and conditions.

Other organisations such as the International Parking Community (IPC), the Independent Appeals Service (IAS) service for parking events in England and Wales, Debt Recovery Plus (DRP), landowners, managing agents, tenants, and any authorised sub-contractors, such as mail service providers, business process outsourcers, credit reference agencies, collection agents, legal advisors, IT service providers, HMCTS, and payment service providers.

What data is shared when you pay online

We will record your IP Address, email address, ticket number and vehicle registration number.

We use PayPal to process our online payments and we do not receive a copy of any credit card number used, expiry date, CSC number, address or telephone number.

Paypal is responsible for the collection, security and integrity of such of any data captured from the Payment web page and processed by the Paypal in an encrypted file.

Paypal assumes responsibility for security and integrity of such transaction data that it may retain in transaction data history files. Where delivery of the transaction data occurs, Paypal assumes responsibility for security, integrity and delivery of such transaction data until such delivery occurs.

Paypal operates and maintains responsibility for keeping in good working order host authorisation and submission of internet transactions including any encrypted data collected and processed by Paypal as part of an authorisation or settlement request originating from the ePayment web site or Portal, including (but not limited to) confidential cardholder data such as credit / debit card numbers, CSC codes, card holder name, address details (where AVS is Used) and authorisation codes approved by the agreed Merchant Services Acquirer (“MSA”) and facilitates upgrades to such systems as agreed between the Paypal and the MSA from time to time.

Although we endeavour to ensure Paypal will do its best to protect your personal data, we cannot guarantee the security of your data entered via Payment web page. These links have their own privacy policies which you should read before transmitting any data and are provided to improve your convenience. Any transmission is at your own risk and you should take the appropriate steps in respect of this risk.

How long we keep your data for

here are certain reasons why we keep hold of some of your data. How long we keep your data for depends upon the type of data we hold and the purpose(s) for which it was collected and processed.

We will store your personal data for no longer than necessary to support the purposes explained above.

We retain the personal data we hold about you for up to 6 years from collection in order to respond to any concerns or claims that may arise in that time. This may be extended if related correspondence or claims are on-going, or where a county court judgment has been issued in Combined Parking Solutions Limited favour and remains outstanding.

If you ask us to restrict the way we process your data,, we will retain relevant data on suppression lists. This means that we will keep just enough data about you available to ensure that we continue to comply with your reasonable request.

Your rights as a data subject

Data protection law gives you the following rights. For further information, including to make a request or ask a question about your rights, please contact our Privacy Team using the details provided below.

We will review each request we receive. Under data protection law we do not have to agree with your request but if we refuse your request, we will still contact you within one month to explain why.

To object to the processing of personal data.
In certain circumstances, individuals have the right to object to the processing of personal data. 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.

To access personal data.
Individuals have the right to request a copy of the data held about them. We are required to verify your identity before passing you information and We may contact you upon receipt of your request to clarify your request. We will be unable to process your request until we have all required information.

To be informed about the processing of personal data.
Individuals have the right to be informed about the collection and use of personal data. This information is contained within this privacy policy.

To request that the processing of personal data be restricted.
Individuals may have the right to request the restriction or suppression of personal data. This right will only apply in certain circumstances.

To request that personal data is corrected if it is inaccurate.
Individuals may request that inaccurate personal data is rectified, or completed if it is incomplete.

To ask that personal data be erased.
The right to erasure is also known as ‘the right to be forgotten’ and individuals can request that their personal data is erased. This right will only apply in certain circumstances.

To request to move, copy or transfer personal data (“Data Portability”).
The right to data portability allows individuals to move, copy or transfer personal data easily from one IT environment to another. This right will only apply in certain circumstances.

Rights relating to automated decision making, including profiling
Individuals have the right to be given information about such processing, request human intervention or challenge a decision. This right will only apply in certain circumstances.

Contacting the ICO

If you are concerned about our processing of your data or if you have a privacy related query not answered by this policy, please contact our Privacy Team via email on info@combinedparkingsolutions.co.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.

Contacting Combined Parking Solutions about a privacy related issue

If you have any questions about our privacy policy, how we use your data or your data rights, you can contact us via email at info@combinedparkingsolutions.co.uk