Privacy Policy
1. Scope
All data subjects whose personal data is collected, in line with the requirements of the GDPR.
2. Responsibilities
The IT and Data Governance Committee is responsible for ensuring that this notice is made available to data subjects prior to Town Centre Car Parks LTD T/A CitiPark PLC collecting/processing their personal data.
All Employees/Staff of Town Centre Car Parks LTD T/A CitiPark PLC who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention.
3. Privacy notice
3.1 Who are we?
CitiPark PLC is a company registered in England under number 08837124 whose registered office is at Town Centre House, Merrion Centre, Leeds, West Yorkshire, LS2 8LY. CitiPark PLC is a parking owner / operator, operating throughout the UK. CitiPark PLC provides car parking services through a number of products. These products are:
Contract season permits in monthly, quarterly or annual options for both business customers and members of the public.
Partnerships;, this is a product issued to a member of the public or a business customer to be used as a discount card offering a preferential rate for parking services.
Short-tTerm pParking customers;, this is the standard product available to all customers whereby a customer uses the car parks in the standard fashion.
Prebooking parking;, thisprebooking is a service available through the CitiPark website and mobile application. This is parking booked and paid for in advance.
The IT and Data Governance Committee can be contacted directly here:
ITDGC@citipark.co.uk
+44(0) 113 2221234
The personal data we would like to collect from you is:
Personal data type:
Name
Address Information
Contact Phone number
Email Address
Payment Details
CCTV Images
Vehicle Registration (VRM)
Entry and Exit times
The personal data we collect will be used for the following purposes:
Payment Processing of contract parking permits
Correspondence relating to your parking products
Gain access into the car parks through Automatic Number Plate Recognition
Offer preferential rates based on emissions data which has been obtained using VRM
Ensure terms and conditions of a car park are adhered to, in the event they are not adhered to personal data may be passed to third-party partners to enforce.
Our legal basis for processing for the personal data:
Performance of Contract
Legitimate Interests
Legal Obligation
Any legitimate interests pursued by us, or third parties we use, are as follows:
To ensure smooth operation of CitiPark car parks
Rate calculations based on vehicle emissions
CitiPark PLC Statistics and Analytics
CitiPark PLC does not collect special categories of personal data from you.
3.2 Disclosure
Town Centre Car Parks LTD T/A CitiPark PLC will pass on your personal data to third parties without first obtaining your consent. The following third parties will receive your personal data for the following purpose as part of the processing activities.
Third country (non-EU)/international organisation
Zendesk – Customer Support helpdesk. Location: U.S.
SurveyMonkey Inc. – Wufoo Online Form provider: U.S.
Safeguards in place to protect your personal data
Privacy Shield and Binding Corporate Rule
Privacy Shield
Retrieve a copy of the safeguards in place here:
http://citipark.co/Zendesk_ps http://citipark.co/Zendesk_bcr
http://citipark.co/surveymonkey_ps
http://citipark.co/surveymonkey_GDPR
3.3 Retention period
Town Centre Car Parks LTD T/A CitiPark PLC will process personal data for the duration of your parking period / contract and will store the personal data for:
Data Ref: SE01
Type of Data: Name, Address, Contact number, VRM, Payment details, Email address
Purpose of Data: Performance of parking contract. Enabling access into CitiPark Branches using Automatic Number Plate Recognition
Review Period: As Required
Retention Period or Criteria: 6 years following the end of contract period
Data Ref: CC01
Type of Data: Name, Address, Contact number, VRM, Payment details, Email address
Purpose of Data: Performance of commercial parking contract. Enabling access into CitiPark Branches using Automatic Number Plate Recognition
Review Period: As Required
Retention Period or Criteria: 6 years following the end of contract period
Data Ref: PA01
Type of Data: Name, Address, Contact number, VRM, Email address
Purpose of Data: Provision of partnership parking, we need your details so we can create your product and provide you with preferential rates.
Review Period: As Required
Retention Period or Criteria: Following 6 months of inactivity on account
Data Ref: PR01
Type of Data: Name, Contact number, VRM, Payment details, Email address
Purpose of Data: When prebooking a parking space through the CitiPark Website. We need these details to send you confirmation and allow access to the car parks using ANPR
Review Period: As Required
Retention Period or Criteria: 12 months following parking transaction.
Data Ref: CI01
Type of Data: Name, Address, Contact number, Email address
Purpose of Data: Provision of CitiPass parking, we need your details so we can create your product and provide you with preferential rates.
Review Period: As Required
Retention Period or Criteria: Following 6 months of inactivity on account
Data Ref: PB06
Type of Data: Name, Address, Email address, Contact Number, Photographs / CCTV, Hospital records
Purpose of Data: Sometimes complaints or incident reports may require you to provide additional information. This information is used for the purpose of handling your case appropriately.
Review Period: As Required
Retention Period or Criteria: 3 years – Statutory time for legal proceedings
Data Ref: PB07
Type of Data: Name, Address, Email address, Contact Number, Bank Statements, VRM
Purpose of Data: When we issue a refund we may require proof of payment and contact details to send refunds to you.
Review Period: As Required
Retention Period or Criteria: 6 years
Data Ref: PB08
Type of Data: VRM
Purpose of Data: When you park with us at CitiPark we record your vehicle registration. This allows us to give smooth ingress and egress from the branches using the ANPR. In some branches we also perform a tariff switch for drivers with lower emissions
Review Period: As Required
Retention Period or Criteria: 12 months following parking transaction.
Data Ref: HS01
Type of Data: Names, Addresses, email addresses, details of incidents, details of contractors
Purpose of Data: If an incident is reported in one of our branches we may require further information to support the report.
Review Period: As Required
Retention Period or Criteria: 3 years – Statutory time for legal proceedings
Data Ref: PB09
Type of Data: Name, Address, Contact Number, email address
Purpose of Data: When contacting CitiPark with general enquiries we require your contact details so we can contact you regarding you query
Review Period: As Required
Retention Period or Criteria: 12 months
Data Ref: PB10
Type of Data: Still and Moving Images or natural persons or VRM
Purpose of Data: Recording of CCTV Across all branches.
Review Period: None
Retention Period or Criteria: Rolling 30 Day period
Data Ref: PB11
Type of Data: Still and Moving Images or natural persons or VRM
Purpose of Data: After an incident is reported CCTV is exported to support the incident if footage is available
Review Period: None
Retention Period or Criteria: 3 years – Statutory time for legal proceedings
3.4 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review: in the event that Town Centre Car Parks LTD T/A CitiPark PLC refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.
3.5 Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Town Centre Car Parks LTD T/A CitiPark PLC (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Town Centre Car Parks LTD T/A CitiPark PLC’s data protection representatives The IT and Data Governance Committee.
The details for each of these contacts are:
Supervisory authority contact details
Contact Name: Information Commissioners Office
Address line 1: Wycliffe House
Address line 2: Water Lane
Address line 3: Wilmslow
Address line 4: Cheshire
Address line 5: SK9 5AF
Telephone: +44 (0)303 123 1113
The IT and Data Governance Committee contact details
Contact Name: The IT and Data Governance Committee
Address line 1: Town Centre House
Address line 2: Merrion Centre
Address line 3: Leeds
Address line 4: West Yorkshire
Address line 5: LS2 8LY
Email: ITDGC@citipark.co.uk
Telephone: +44 (0)113 222 1234
3.6 Privacy statement
Read more about how and why we use your data here https://citipark.co.uk/pages/privacy-policy
4. Online privacy statement
Personal data
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information
This privacy notice tells you how we, Town Centre Car Parks LTD T/A CitiPark PLC, will collect and use your personal data for services and activities relating to parking using the various products available from CitiPark PLC both online and in our carparks that personal data is collected for. These services include contacting us relating to enquiries and complaints, cookies, profiling, online purchases for prebooking and contract parking and registration for partnership parking.
__zlcmid
We use Zopim to provide live customer service chat on our Site. This cookie contains your Zopim Live Chat ID to identify your device during visits. Please visit Zopim Privacy Policy for further details (https://www.zendesk.com/company/customers-partners/#cookie-policy)
__cfduid
Zopim uses Cloudflare to serve assets required to make it’s live chat service work. Cloudflare uses this cookie to identify your device in order to establish whether it is trusted or not. Please visit Cloudflare for more details about this cookie (https://support.cloudflare.com/hc/en-us/articles/200170156-What-does-the-Cloudflare-cfduid-cookie-do-)
eggbasket
We run a campaign each year, usually around Easter where we hide easter eggs on our website. This cookie keeps track of how many (and which ones) you’ve found.
ga, cookies beginning with gat, gid
We use Google Analytics to collect information how visitors use our Site, which pages are most frequently visited and record if advertising is effective or not. Please visit Google Privacy Policy (http://www.google.com/analytics/learn/privacy.html) for details. If you want to opt out of Google Analytics for all sites, you can download an addon for your browser (https://tools.google.com/dlpage/gaoptout/)
Google Remarketing, DoubleClick, Microsoft Advertising
We may use Remarketing with Google Adwords, Microsoft Advertising and third-party remarketing services (eg DoubleClick) to make our online ads more relevant. The remarketing cookies help to serve our ads at a later time when you are browsing sites on the web. Remarketing cookies expire after 30 days and are not used for personal identification. To opt out of third-party interest-based advertising, please visit Network Advertising Consumer Opt-outpage (http://www.networkadvertising.org/choices)
NREUM, JSESSIONID
We use New Relic to monitor the performance of our Site and notify us if any of our web servers should have problems. Please visit New Relic Privacy Policy for details (https://newrelic.com/termsandconditions/privacy)
laravel_session
We use a platform called Laravel to enable customers to log into their accounts. This cookie stores a session which links your device to your account. It is only used to authenticate you between requests, not to track your behaviour or for advertising.
Why does Town Centre Car Parks LTD T/A CitiPark PLC need to collect and store personal data?
In order for us to provide you with parking services we need to collect personal data for the provision of services including access into and exit from our car park locations, ensuring smooth operation and efficiency of CitiPark PLC car parks and services.
In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy.
In terms of being contacted for marketing purposes Town Centre Car Parks LTD T/A CitiPark PLC would contact you for additional consent.
Stripe Payments
CitiPark uses stripe payments on both the Android/iOS mobile apps. This requires information about your phone number and apps installed on the device in order to ensure secure and successful payment.
Will Town Centre Car Parks LTD T/A CitiPark PLC share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Town Centre Car Parks LTD T/A CitiPark PLC in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to process payments made to CitiPark PLC. When they no longer need your data to fulfil this service, they will dispose of the details in line with GDPR Compliance.
How will Town Centre Car Parks LTD T/A CitiPark PLC use the personal data it collects about me?
Town Centre Car Parks LTD T/A CitiPark PLC will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Town Centre Car Parks LTD T/A CitiPark PLC is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Town Centre Car Parks LTD T/A CitiPark PLC contact me?
Our aim is not to be intrusive, and we endeavour not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Town Centre Car Parks LTD T/A CitiPark PLC, at your request, can confirm what information we hold about you and how it is processed. If Town Centre Car Parks LTD T/A CitiPark PLC does hold personal data about you, you can request the following information:
Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of Town Centre Car Parks LTD T/A CitiPark PLC or a third party, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority.
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
Town Centre Car Parks LTD T/A CitiPark PLC accepts the following forms of ID when information on your personal data is requested:
Passport, driving licence, birth certificate, utility bill (from last 3 months)
Contact details of the Data Protection Officer / The IT and Data Governance Committee:
The IT and Data Governance Committee contact details
Contact Name: The IT and Data Governance Committee
Address line 1: Town Centre House
Address line 2: Merrion Centre
Address line 3: Leeds
Address line 4: West Yorkshire
Address line 5: LS2 8LY
Email: ITDGC@citipark.co.uk
Telephone: +44 (0)113 222 1234
Document Owner and Approval
The IT and Data Governance Committee is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.
A current version of this document is available to all members of staff on the corporate file store.
Change History Record:
Issue: 1
Description of Change: Initial issue
Approval: Peter Dowling
Date of Issue: 25th May 2018