N W Car Parks Ltd (NWCP) manages parking on behalf of private land owners. When processing your personal data we are defined as the ‘controller’ under the data protection laws.

Our Registered address is - N W Car Parks Ltd, 4 Croft Court, Whitehills Business Park, Blackpool, FY4 5PR. We are registered as a Data Controller with the Information Commissioners Office and our reference number is ZA183374. 

This policy was last updated on 25/10/2022.

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 your rights as a data subject

This Privacy Policy has been produced in light of the General Data Protection Regulations (GDPR) 2018 and applies to all personal data, as defined in the Regulations. NWCP will collect information you supply via this website, such information may include your name, postal address, email address and telephone number in order to respond to your enquiry or appeal. Information supplied to us is subject to confidentiality and will not be disclosed without your prior consent other than to the IPC, POPLA, mail service providers, credit reference agents, collection agents or solicitors for this purpose and any authorised sub- contractors if provided in relation to a Parking Charge Notice.

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.

Any changes to this policy will be posted on our website so that you may be aware of the information that N W Car Parks Ltd collect and how it is used at all times and your continued use of the website will be your acknowledgement of your agreement to the new policy.

What data do we process when you use our car parks?

When you use a car park that is managed by N W Car Parks Ltd, we collect and process data which can include the Vehicle Registration Number (VRN), time and movements of the vehicle and images of the vehicle.

If the terms and conditions of the car park are breached, a Parking Charge Notice will be issued. The data we process when issuing a Parking Charge Notice includes the recipient’s name and address, images of the vehicle, its details and movement whilst using the car park and the Vehicle Registration Number (VRN).

If you submit an appeal in relation to a Parking Charge Notice issued, or otherwise correspond with us, including on the phone, you may provide us with additional personal data, the data we process could include: you full name and postal address, email and phone number; a Parking Charge or other reference number; the capacity in which you are appealing (e.g. as the keeper, driver or hirer); and any other information you provide within any correspondence with NWCP, phone call or appeal such as copy of your online Parkonomy booking.

How do NWCP collect data?

Images of vehicles and VRNs are collected either via Automated Number Plate Recognition (ANPR) cameras that are on site or by one of our parking attendants who manually patrol the car park. Where in operation VRN data may also be collected and processed via the data logs linked to our ticket machines/online booking platform Parkonomy.

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 Licensing Agency (DVLA) or an international equivalent.

If you are not the Registered Keeper of the vehicle, then your data will have been provided by one of the following:

• a third party who has confirmed that you were responsible for the vehicle on the date/time the Parking Charge Notice was issued;
• a third party who has confirmed that you were driving the vehicle on the date/time the Parking Charge Notice was issued;
• or a third party who has confirmed that the vehicle was on hire or leased to yourself on the date/time the Parking Charge Notice was issued

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.

What if sensitive data is provided in an appeal lodged or correspondence sent to NWCP?

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

Examples include personal identity numbers, any financial account information such as bank details, information about an individual’s racial or ethnic origin, sexual orientation, political opinions, religious, philosophical or information regarding an individual’s health/medical condition.

We will not ask you for any more information than we need, and we do not keep your information for any longer than we need to or as required by law or a government body. 

We take reasonable steps to keep your details up to date and accurate. Please bear in mind that we may hold your records after your appeal has been considered as we are required to have an effective audit trail and to comply with regulatory and legislative requirements.

The General Data Protection Regulations (GDPR) give you the right to access information held about you. You can access personal data we have about you by writing to us at N W Car Parks Ltd, 4 Croft Court, Whitehills Business Park, Blackpool, FY4 5PR or by emailing info@nwcarparks.co.uk .

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 Notice remain open.

Please contact us using the details provided above (ensuring you provide proof of identification when emailing) if:

•  you object to your personal details being processed, or
• you believe we hold the incorrect details for you and would like us to rectify the data we hold, or
• you would like us to delete the data we hold for you, or
• you would like to restrict how we process your data, or
• if you entered into a contract with us and would like a copy of the data we hold about you in a format which can be easily transferred to another provider.

Please note that you have a right to request the above, however, when we receive your request we may object if we do not agree, this will apply if there are still outstanding charges or county court judgments entered against you. When you do make the request we will tell you if the request has been granted or not within 28 days.

How and why do NWCP process data?

When using car parks managed by N W Car Parks Ltd, personal data is collected and processed for the purposes of:

• to ensure compliance with the terms and conditions of the car park, and the contract entered into when you entered and remained on the car park as detailed on the signage;
• issuing a Parking Charge Notice when the car parks terms and conditions have been breached;
• 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 affective car park management services to land owners and local businesses

Our lawful basis for processing data is:

1. the processing is necessary for a contract which has been entered into

2. there is a legitimate interest as detailed below;

a) to pursue motorists for an unpaid parking tariff

b) to pursue motorist for unpaid parking charges

c) to administer an appeal relating to a  parking charge notice

If you are the driver of a vehicle using a car park managed by N W Car Parks Ltd, 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 the signage throughout the car park, and to enforce those terms and conditions where necessary.

NWCP will also process data in pursuit of our, the landowners, and the public’s legitimate interests, this includes:

• the enforcement of breaches of the terms and conditions where the recipient of the Parking Charge was not the driver of the vehicle. Enforcement of breaches of the 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 International Parking Communities (IPC) Code of Practice. Where the Parking Charge was issued in England and Wales, this includes an opportunity for all motorists to lodge a further appeal with the Independent Appeals Service (IAS) should the initial appeal be rejected by us.
• Progressing the Parking Charges Notice 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 overall customer experience, this could consist of any of the following:

 a) Displaying images of vehicles on payment machines and/or terminals to assist car park users to identify their entry time and select the appropriate tariff payment.

b) 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.

c) Carrying out data analytics, including reporting on vehicle turnover, vehicle type and repeat visits.

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

e) As part of the audit processes undertaken by the DVLA and IPC on a regular basis.

Who do NWCP share data with?

In order to enforce the parking contract where a breach has been identified and to support the legitimate interests as previously explained above, where a Parking Charge Notice is payable we may request/share data with:

• 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) for parking events in England and Wales, landowners, and any authorised sub-contractors, such as mail service providers, business process outsourcers, credit reference agencies, collection agents, legal advisors, IT service providers, and payment service providers

How long will NWCP keep data for? 

There 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.

Your data will be retained for sufficient time to enable the fee to be settled, by you or another person and resolve any dispute 

We will store your personal data for no longer than necessary to support the purposes and our legitimate interest as explained above. 

Your data will not normally be held for longer than 6 years in such circumstances, however in some circumstances your data may be held for longer than 6 years, examples of when we may hold your data for longer are:

1. where there is an ongoing dispute which requires us to hold the data for longer than normal

2. where a county court judgment or order has been made has been made allowing us to pursue outstanding monies owed to NWCP after the expiration of 6 years

Your personal data may be shared with third parties. This may include, debt recovery companies, solicitors and bailiffs to pursue any outstanding debts. If you also decide to challenge a Parking Charge Notice and we reject your appeal, then we will provide your PCN number, vehicle registration, the time and date of the parking charge being issued along with all photographic evidence captured to the Independent Appeals Service (IAS) which is a DVLA Accredited Trade Association (ATA). 

What data is processed when I pay a Parking Charge Notice online through the NWCP website?

We use Ecom6 and Credorax as payment service providers (PSP) to process payments on our website. When making a payment you will be taken to a separate ePayment web page or portal, hosted and administered by the PSP, and you will leave the NWCP website.

When you click on the ‘CLICK HERE’ button on the websites ‘Payment’ (https://www.nwcarparks.co.uk/payment) and ‘Your PCN’ (https://www.nwcarparks.co.uk/your-pcn) pages you will be taken to the Ecom6 ePayment web page/ portal.

The ePayment web page/portal (https://nwcarparks.ec6pay.com/) will then ask you enter the Parking Charge Notice number and Vehicle registration and to click ‘Submit’.

After clicking ‘Submit’ the ePayment web page/portal will then bring up the Parking Charge Notice details such as the photographic evidence which has been captured and the vehicles details.

When you click on the ‘Pay Now’ button you will then be asked to enter the debit/credit card details so payment can be taken.

The data processed whilst you make payment of a Parking Charge Notice will include the PCN number, vehicle registration, your email address and phone number (optional), your debit/credit card number, expiry date and security code. 

The PCN number entered will be used for the purpose of locating the relevant Parking Charge Notice issued to enable the PSP to populate the payment screen with the correct outstanding amount payable and any other details will be used by the PSP to process the transaction.

Data Security

The PSP (Ecom6 & Credorax) is responsible for the collection, security, and integrity of such of any data captured from the ePayment web page or portal/gateway collected and processed by the PSP in an encrypted file. 

The PSP 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, the PSP assumes responsibility for security, integrity, and delivery of such transaction data until such delivery occurs.

The PSP operates and maintains responsibility for keeping in good working order host authorization and submission of internet transactions including any encrypted data collected and processed by the PSP as part of an authorization 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, cardholder name, address details (where AVS is Used) and authorization codes approved by the agreed Merchant Services Acquirer (“MSA”) and facilitates upgrades to such systems as agreed between the PSP and the MSA from time to time.

Although we endeavour to ensure the PSP will do its best to protect your personal data, we cannot guarantee the security of your data entered via ePayment web pages, apps, or portals. 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.

Contacting the Information Commissioner’s Office

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 team using the contact details below. 

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).

What are my rights as a data subject?

Data protection law gives you the following rights:

• 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. NWCP 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 the 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, within the signage located on all sites managed by us and on our website at https://www.nwcarparks.co.uk/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. We may decline your request for personal data to be erased, if the law requires us to do so or if you have an outstanding Parking Charge Notice. We will advise you with 28 days, by writing, if we decline your request and outline the reasons why.

• 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 N W Car Parks Ltd for other privacy related queries

If you have any further questions about our privacy policy which are not outlined or clearly answered in the above, you can contact us by  emailing info@nwcarparks.co.uk .