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To: Michelle Donelan (Secretary of State for Science, Innovation and Technology)

PRIVACY OVER PROFIT: Restrict the use of ANPR in the private sector

Photo by Isaac Chou on Unsplash
The government should introduce new legislation to: Restrict the use of ANPR technology in the public sector for the purposes of contract monitoring and data analysis.

Private parking companies should have to manually check that their customers are complying with the terms of their contracts through the use of parking attendants alone. Not only would this prevent the unnecessary invasion of people’s privacy, it would present job opportunities for the millions presently out of work in the UK.

Why is this important?

People's privacy should be respected! Their movements should NOT be monitored by big corporations for the purpose of managing contracts and increasing profits. The use of ANPR technology and associated data analysis should be reserved for the prevention and detection crime, or the enforcement of civil laws.

Automatic Number Plate Recognition (ANPR) technology is something most people will now be familiar with. Used correctly, it is invaluable in the fight against crime and disorder. Used incorrectly, it can be used to invade people’s privacy and boost profits for greedy companies in the private sector.

The problem....

ANPR has been around for a number of years. It was designed to enable law enforcement agencies to prevent and detect crime and other offences. More recently, however, private parking companies have been using ANPR cameras to monitor breaches of contracts and worse still ‘MONITOR CAR PARK USAGE, IDENTIFY TRENDS AND PREDICT CUSTOMER BEHAVIOURS’.

Let’s be very clear here; when you don’t park correctly or overstay in a private car park, you DO NOT commit a criminal or civil offence, you breach a contract with the parking provider. The use of ANPR cameras is therefore not being used to prevent and detect crime or offences as set out in legislation, instead it is enabling large companies to further increase profits by allowing them to observe our vehicle use remotely. Using ANPR to invade people’s privacy in this way is not proportionate or necessary, but IS currently legal.

How it works....

ANPR cameras at the entrance of a private car park detect the number plate of a vehicle upon entry, recording the time, date and sometimes the make / model of vehicle. They also capture an image of the vehicle, as well as the occupants, if the camera is of a high quality. Another camera at the exit performs a similar function. The captured data from both cameras is compared to see if the car park user has breached the parking contract by overstaying or parking incorrectly.

More worryingly, the data can be used to analyse the days, times and durations of people’s stays at the locations, or in the words of one parking company ‘MONITOR CAR PARK USAGE, IDENTIFY TRENDS AND PREDICT CUSTOMER BEHAVIOURS’. The parking companies then share this data, which includes: ‘Live car park occupancy, Heat maps of peak occupancy, Capacity and utilisation, Dwell times, Revenue, Vehicle details (make, model, colour, fuel type), Vehicle of interest alerts’. NB - If you’re wondering what the last category means, one such company refers to it as a way of knowing when ‘vehicles owned by undesirables, trouble-makers, or criminals arrive in your car park.’ Whilst that sounds like a positive thing, unlike in law enforcement, there are no rules governing which vehicles / individuals can be placed on the ‘hotlist’. They can therefore deem any vehicle, they so wish, to be a ‘vehicle of interest’ and pass that information to their client. In the case of a supermarket car park for instance, in theory, the parking provider could be alerting shop staff every time young people dressed in scruffy clothing arrive at their location. This could then give security staff an opportunity to unnecessarily follow and monitor those individuals, or ‘undesirables’ as one of the companies so eloquently calls them.

Although customers are advised ANPR is used at car parks, they are not advised as to exactly HOW and WHY it is used. One company only says that parking is ‘camera’ monitored at the entrance points and is not specific as to what type of cameras are used.

Ultimately, parking companies are charging their clients (shopping centres, supermarkets, local councils) for services that ONLY INCREASE PROFITS. The services do not enable laws to be enforced or crime prevented. The parking companies themselves are paid handsomely for what they offer their clients, with CEOs reportedly earning more than the Prime minister, while all they have to do is sit back and let their computer programs do the work for them.

Potential consequences...

The misuse of ANPR technology, in the way described, means that private companies can know when and where you are going and for how long. They can know what car you drive and in some cases, even what you look like.

Whilst such companies will be keen to tell you that they look after your personal data, the past few months have seen data breaches within even the most secure organisations (police, NHS, etc.) Imagine how valuable it may be to criminals to know where you are likely to be at a given time and for how long. It’s a scary thought, but sadly not an unlikely eventuality, so long as this application of ANPR is allowed to continue.

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Updates

2023-11-05 10:54:37 +0000

If TFL can't use ANPR and CCTV as the primary means of parking enforcement, then private companies should be stopped too!

The article in the link follows the campaign aimed at stopping TFL using CCTV and ANPR as its primary means of parking enforcement in London. The decision of the court is awaited, but the campaign appears to have real momentum. Should TFL be legally prevented from using CCTV and ANPR before parking wardens, this should have a knock on effect in the private parking sector. After all, what the public needs is consistency and fairness!
https://www.telegraph.co.uk/news/2023/11/04/tfl-must-end-use-cctv-anpr-war-on-motorists-court-told/