AUTOMATED LICENSE PLATE RECOGNITION PRIVACY POLICY

Washington State University Pullman Campus

Washington State University (WSU) utilizes automated vehicle license plate recognition (ALPR) hardware and software for its parking system. ALPR and pay-by-plate technology specifically connect campus-parking permits to individual vehicle license plates. These technology improvements significantly enhance and simplify customer experience, enforcement, and parking lot utilization analysis.

Locations

ALPR data is collected on the WSU Pullman campus streets, parking lots and parking areas, and other areas that WSU is or may become responsible for (see Campus Parking Map here). ALPR data is collected by cameras positioned on a mobile vehicle-mounted system and fixed cameras. Any “ALPR vehicle” is driven by trained personnel in parking locations throughout the WSU Pullman campus. ALPR vehicles can be active 24 hours daily, 7 days per week.

Prohibited practices concerning ALPR:

• Disclose, share, or permit access to ALPR data except as required in a judicial proceeding.
• Provide direct access to its ALPR system to any entity except for other agencies authorized to use an ALPR system.
• Collect ALPR data on the premises or immediate surroundings of elementary or secondary schools, places of worship, courts, food banks, any facility conducting an immigration matter, or facilities that provide protected health care.
• Sell, lease, rent, or purchase ALPR data or audit trail data.

Data Collected

The ALPR system captures two photos of observed vehicles: (1) a context photo of the vehicle and its immediate surroundings and (2) a photo of the license plate. Typically, these photos are taken from the rear of the vehicle, although there are occasions where a photo is taken from the front (e.g. when a car is backed into a parking space). The photos are not of a resolution that allows identification of the vehicle occupants. Along with the photographic data, the system also records the Global Positioning System (GPS) coordinates and date/time information of the observation. Further software processing of the vehicle license plate image generates an alphanumeric version of the vehicle license plate number which is also stored with the parking ALPR record.

Use of Data

The intended use of data collected by the ALPR system is for parking activities and enforcement. ALPR data is used to determine a vehicle’s parking permit permissions in each parking area and support the issuance of a parking citation if needed. The data may be used by the WSU Police Department in assisting immediate or on-going safety concerns and conducting specific security investigations; and compulsory law enforcement investigations. Any use of the data for purposes outside of these stated purposes must be detailed and approved in writing through administrative channels by the Executive Vice President, and Chief Financial Officer of Finance and Operations.

Data Retention

Data collected by the ALPR system, not resulting in parking enforcement action or not part of an ongoing law enforcement investigation, may be retained up to 21 days. Statistical lot utilization data (generic vehicle counts) is retained indefinitely for parking program planning and operations. Data resulting in parking enforcement action is retained with the citation (ticket) records according to established WSU data retention policies. Data associated with an ongoing security and/or law enforcement investigation is retained until the investigation is completed or as directed by investigators or courts and/or in conformance with WSU data retention policies.

Exceptions: when retained for the purpose of parking enforcement, provided the data is deleted no later than 12 hours after final disposition of a parking enforcement case, including exhaustion of any applicable appeals process.

Access to Records

Access to records created and maintained by the ALPR system is restricted to trained WSU parking personnel performing their duties and a limited number of WSU Police Department law enforcement personnel (WSU Public Safety). All personnel with access to the system use unique identifiers and passwords to access records and all login, record additions, and other activities are logged. Access to the system by others is strictly prohibited.

Note that data may be subject to the Washington Public Records Act and subject to legally recognized redaction.

Determining what data, we have about you…?

Students, faculty and staff with a WSU parking account may view information we have about their own individual vehicles at any time by logging onto their WSU parking account.

Public Notification

WSU will notify the public of its ALPR data collection activities and policies via:

• Posting of this privacy policy on the WSU Pullman Transportation Services and website.