Automatic Number Plate Recognition technology is used by Essex Police and Kent Police, to help detect, deter and disrupt criminality at a local, force, regional and national level. It is also used in circumstances of significant public interest and the purposes of public safety such as to assist in locating vulnerable and missing people.

Introduction

This specific privacy notice has been created to make it easier for you to understand what personal data Kent Police and Essex Police could process about you on Automated Number Plate Recognition (ANPR) Systems and how and why it could be used.

This privacy notice is a requirement of the Data Protection Act 2018 (DPA) and the General Data Protection Regulation (GDPR).

It is subordinate to, and should be read in conjunction with, the police forces’ high-level Privacy Notices:

Kent Police specific privacy notice

Essex Police specific privacy notice

The high-level privacy notices provide you with complete details of the rights you have relating to the personal data we may hold about you now and any personal data we might collect about you in the future.

If you require this specific privacy notice in Braille or in another language please contact the force’s data protection officer.

As a vehicle passes an ANPR camera, its ‘number plate’ is read and instantly checked against database records of vehicles of interest. Police officers can intercept and stop a vehicle, check it for evidence and, where necessary, make arrests. A record for all vehicles passing by a camera is stored, including those for vehicles that are not known to be of interest at the time of the read that may in appropriate circumstances be accessed for investigative purposes. The use of ANPR in this way has proved to be important in the detection of many offences, including locating stolen vehicles, tackling uninsured vehicle use and solving cases of terrorism, major and organised crime. It also allows officers’ attention to be drawn to offending vehicles whilst allowing law abiding drivers to go about their business unhindered.

Information collected by both forces’ ANPR Systems is uploaded to the National ANPR Service (NAS). The National ANPR Standards can be found here along with related documentation about the NAS.

The remainder of this document is formed of two sections – the first provides privacy information for where Kent Police and Essex Police ANPR systems are used for law enforcement purposes, while the second covers their use for any other purposes, known as ‘general purposes’.

Law enforcement processing privacy information

Who are the Controllers (the persons who determine the purpose and means by which your personal data could be processed) for the ANPR Systems and what are their contact details?

The joint Controllers are:

Chief Constable of Essex Police
Essex Police Headquarters
PO Box 2 
Chelmsford
CM2 6DA

and

Chief Constable of Kent Police
Kent Police Headqurters
Thames Way
Northfleet
Gravesend
Kent
DA11 8BD

Essex Police acts as the lead Controller for ANPR for the two forces.

DPA Section 44(1)(a)

What are the contact details of the forces’ Data Protection Officers?

Data Protection Officer
Essex Police Headquarters
PO Box 2
Chelmsford
CM2 6DA
Email: [email protected]

Data Protection Officer
Information Management
Kent Police
Coldharbour
London Road
Aylesford
ME20 7SL
Email: [email protected]

DPA Section 44(1)(b)

What personal data of mine could be processed on ANPR Systems by Kent Police and Essex Police?

Kent Police and Essex Police collect and process the following personal data:

  • vehicle registration mark (‘number plate’)
  • image of vehicle
  • location of the ANPR camera that the vehicle passed
  • date and time that the vehicle passed an ANPR camera

For what intended purpose(s) could my personal data be processed within ANPR Systems by Kent Police and Essex Police?

For law enforcement purposes – defined as: the prevention, investigation, detection or prosecution of criminal offences, the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security, or common law policing purposes.

More specifically law enforcement purposes include use for:

Operational response

A vehicle known to be of interest may be circulated on a list of vehicles of interest (VOI) such that when it passes by an ANPR camera an ‘alert’ is created and resources may be deployed to stop the vehicle and deal appropriately with the reason for including the vehicle on the VOI list.

Supporting investigations

Searches of ANPR data can confirm whether vehicles associated with a known criminal has been in the area at the time of a crime and can dramatically speed up investigations.

Intelligence development

Research of data stored within the forces’ ANPR Systems can be of significant benefit in supporting assessment of information and intelligence reports particularly for organised crime investigations that may reduce the need for more intrusive surveillance activity and reduce costs.

DPA Section 44(1)(c)

How could my personal data be processed on ANPR systems by Kent Police and Essex Police?

If collected Kent Police and Essex Police would process your personal data in the following ways:

If your vehicle passes an ANPR camera its ‘number plate’ will be read and this information together with the location of the camera, the time your vehicle passed the camera and an image of the vehicle will be recorded on the ANPR systems. That information will be stored for a period of time by Kent Police and Essex Police and a copy sent to the National ANPR Service. The information may be accessed by officers and staff working for the two forces where required for general processing purposes. Where appropriate the information will be used or disclosed for those purposes. Ultimately the information will be deleted.

What are my rights under the DPA?

You have the following rights under the DPA:

  • right of access to your personal data Section 44(1)(d)(i) Section 45
  • right of rectification of your personal data Section 44(1)(d)(ii) Section 46
  • right of erasure of your personal data or the restriction of its processing Section 44(1)(d)(iii) Section 47
  • right to lodge a complaint with the Information Commissioner Section 44(1)(e) Section 51

Full details of those rights and how to exercise them can be found in Essex Police’s high-level privacy notice and the Kent Police privacy notice. They can also be obtained from:

Information Rights Team
Essex Police Headquarters
PO Box 2
Chelmsford
CM2 6DA
Email: [email protected]
 
and

Public Disclosure Team
Kent Police
Coldharbour
London Road
Aylesford
ME20 7SL
Email: [email protected]

Is there any other information that is necessary to enable me to exercise any of rights listed at 'What types of personal data do we process in the overarching privacy notice?

None identified.

DPA Section 44(2)(d) and Section 44(3)(a)

What would be Kent Police and Essex Police’s legal bases for processing my personal data within the ANPR systems?

Kent Police and Essex Police’s legal bases for processing personal data on the ANPR systems are derived from their common law policing purposes of protecting life and property, preserving order, preventing the commission of offences, bringing offenders to justice, and any duty or responsibility of the police arising from common or statute law.

In terms of Section 35(2) of the DPA the processing is necessary for the performance of a task carried out for a law enforcement purpose by Kent Police, Essex Police or another competent authority.

DPA Section 44(2)(a) and Section 35(2)

How long could my personal data be retained in ANPR systems by Kent Police and Essex Police?

Personal data is deleted from the forces’ ANPR systems within 24 hours after the period of seven days following the capture of the information, subject to the requirements of the Criminal Procedures and Investigations Act 1996.

Where of evidential or investigative value the data is copied to other police systems and retained as long as is necessary in accordance with the requirements of the Data Protection Act 2018, the College of Policing’s Authorised Professional Practice on the Management of Police Information, and Criminal Procedures and Investigations Act 1996.

Details of vehicles of interest are deleted when no longer required or automatically deleted 28 days after their last revision, whichever is the sooner.

Personal data that has been shared by the forces with the National ANPR Service will be retained on the National ANPR Service for 12 months unless provisions of the Criminal Procedures and Investigations Act 1996 apply when it may then be preserved for a longer period.

DPA Section 44(2)(b)

Who could Kent Police and Essex Police disclose my personal data to from the ANPR systems?

The personal data from the ANPR systems is disclosed to the National ANPR Service.

It may be shared with other law enforcement agencies within the UK and abroad, other competent authorities and Criminal Justice agencies.

DPA Section 44(2)(c)

General processing privacy information

Who are the Controllers (the persons who determine the purpose and means by which my personal data could be processed) for the ANPR systems and what are their contact details?

The joint Controllers are:

Chief Constable of Essex Police
Essex Police Headquarters
PO Box 2 
Chelmsford
CM2 6DA

and

Chief Constable of Kent Police
Kent Police Headquarters
Thames Way
Northfleet
Gravesend
Kent
DA11 8BD

Essex Police acts as the lead Controller for ANPR for the two forces.

DPA Article 13(1)(a) and Article 14(1)(a)

What are the contact details of the forces’ Data Protection Officers?

Data Protection Officer
Essex Police Headquarters
PO Box 2
Chelmsford
CM2 6DA
Email: [email protected]

Data Protection Officer
Information Management
Kent Police
Coldharbour
London Road
Aylesford
ME20 7SL
Email: [email protected]

DPA Article 13(1)(b) and Article 14(1)(b)

What personal data of mine could be processed on ANPR systems by Kent Police and Essex Police?

Kent Police and Essex Police collect and process the following personal data on ANPR systems:

  • vehicle registration mark (‘number plate’)
  • image of vehicle
  • location of the ANPR camera that the vehicle passed
  • date and time that the vehicle passed an ANPR camera

For what intended purpose(s) could my personal data be processed on ANPR systems by Kent Police and Essex Police?

For general purposes including:

  • in circumstances of significant public interest
  • public safety such as to assist in locating vulnerable and missing people
  • enforcement of the collection of any tax or duty by police and other agencies

DPA Article 13(1)(c)

How could my personal data be processed on ANPR systems by Kent Police and Essex Police?

If collected Kent Police and Essex Police would process your personal data in the following ways:

If your vehicle passes an ANPR camera its ‘number plate’ will be read and this information together with the location of the camera, the time your vehicle passed the camera and an image of the vehicle will be recorded on the ANPR systems. That information will be stored for a period of time by Kent Police and Essex Police and a copy sent to the National ANPR Service. The information may be accessed by officers and staff working for the two forces where required for general processing purposes. Where appropriate the information will be used or disclosed for those purposes. Ultimately the information will be deleted.

What are Kent Police and Essex Police’s legal bases for processing my personal data on ANPR systems?

Kent Police and Essex Police’s legal bases for processing the personal data from the ANPR system are for one of the following:

  1. the processing is necessary for compliance with a legal obligation to which either Chief Constable is subject
  2. the processing is necessary in order to protect the vital interests of the data subject or of another natural person
  3. the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

DPA Article 13(1)(c) and Article 14(1)(c)

If my personal data within ANPR systems was obtained by Kent Police or Essex Police from someone else what are the categories of personal data collected?

Personal data may be obtained from cameras operated by other organisations such as Highways England and local authorities. The categories of personal data collected in this way will be the ‘number plate’, the location of the camera, the time your vehicle passed the camera and an image of the vehicle.

DPA Article 14(1)(d)

Who could my personal data within ANPR system be disclosed to by Kent Police or Essex Police?

The personal data could be disclosed to a wide range of bodies, but only where it was lawful under data protection and other legislation and proportionate to do so.

DPA Article 13(1)(e)

Do Kent Police or Essex Police intend to transfer personal data from the ANPR systems out of the UK or to an international organisation?

No.

DPA Article 13(1)(f) and Article 14(1)(f)

If Kent Police or Essex Police intend to transfer personal data from ANPR systems out of the UK or to an international organisation what safeguards are there to protect that personal data?

Not applicable.

DPA Article 13(1)(f) and Article 14(1)

How long could my personal data be retained by Ken Police and Essex Police within ANPR systems?

Personal data is deleted from the forces’ ANPR systems within 24 hours after the period of seven days following the capture of the information, subject to the requirements of the Criminal Procedures and Investigations Act 1996.

Details of vehicles of interest are deleted when no longer required or automatically deleted 28 days after their last revision, whichever is the sooner.

In addition, where the data is required for general processing purposes it will be copied from the ANPR systems and retained as long as is necessary in accordance with the requirements of the Data Protection Act 2018, and in accordance with the forces’ procedure W1012 Records Review, Retention and Disposal.

DPA Article 13(2)(a) and Article 14(2)(a)

What are my rights under the GDPR? You have the following rights under the GDPR:

  • right to be informed
  • right of access
  • right of erasure
  • right to restriction of processing
  • right to data portability
  • right to object
  • right not to be subject of automated decision-making

Full details of those rights and how to exercise them can be found in Essex Police’s high-level privacy notice and the Kent Police privacy notice. They can also be obtained from:

Information Rights Team
Essex Police Headquarters
PO Box 2
Chelmsford
CM2 6DA
Email: [email protected]

and

Public Disclosure Team
Kent Police
Coldharbour
London Road
Aylesford
ME20 7SL
Email: [email protected]

DPA Article 13(2)(b) and Article 14(2)(c)

If Kent Police or Essex Police rely on my consent to be the legal basis for processing my personal data on the ANPR systems can I withdraw that consent?

Neither police force relies on your consent as a basis to process your personal data.

DPA Article 13(2)(c) and Article 14(2)(d)

Who can I lodge a complaint with if I am unhappy about the way my personal data is processed on ANPR systems by Kent Police or Essex Police?

You may lodge a complaint with the Information Commissioner’s Office. Their contact details are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website:  www.ico.org.uk

You may wish to initially raise any concerns with the Kent Police Data Protection Officer or the Essex Police Data Protection Officer.

DPA Article 13(2)(d) and Article 14(2)(e)

If my personal data could be obtained by Kent Police or Essex Police from someone else for the ANPR systems from who or where could it be obtained?

Personal data may be obtained from cameras operated by other organisations such as Highways England and local authorities.

DPA Article 14(2)(f)

Am I required to provide my personal data for the ANPR systems under a statutory or contractual requirement, or a requirement necessary to enter into a contract, or am I obliged to provide it?

No.

DPA Article 13(2)(e)

Could my personal data on the ANPR systems be used for automated decision-making, including profiling?

No, decision will be made without the involvement of a police officer or member of police staff.

DPA Article 13(2)(f) and Article 14(2)(g)

If my personal data on ANPR systems was used for automated decision-making, including profiling what logic will be involved and what significance and consequences will there be for me from the automated decision-making?

Not applicable.

DPA Article 13(2)(f) and Article 14(2)(g)

 

Revised 28 January 2020. Version 1.0