LPR and DOL Data Privacy Notice
Western Washington University
Transportation Services
Privacy Notice
Purpose of Notice
This notice provides information for its employees, students, and visitors about Western’s use of license plate recognition (LPR) hardware and software for vehicle parking enforcement and citation collections. If a driver does not wish for the University to collect such data, the driver may choose not to use parking areas and services managed by Western Washington University Transportation Services.
USE OF LICENSE PLATE READERS (LPR)
Locations
LPR data is collected by Transportation Services (TS) on University managed or owned streets, parking lots and structures, as well as any location associated with a current university lease, rental or mutual‐aid agreement. TS utilizes mobile vehicle‐mounted systems and/or handheld devices, which are driven or operated by trained personnel in parking locations throughout the university and associated areas included in this policy. Mobile cameras are active 24 hours daily, 7 days per week.
Data Collected
The LPR system captures two photos of observed vehicles:
- A context photo of the vehicle and its immediate surroundings, and
- 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 of a vehicle backed into a space or standing in a driving aisle. Along
with the photographic data, the system also records the global positioning system coordinates and date/time information of the observation. Further software processing of the license plate image generates an alphanumeric version of the license plate number, which is also stored with the record.
While no owner or driver information is stored directly with the LPR record, vehicle LPR data is linked to individual patron accounts within the parking management system.
Use of Data
The intended use of data collected by the LPR system is for parking access control, parking
enforcement and for active criminal investigations. LPR data is used to determine a vehicle’s access permissions in each parking area or controlled access area of campus and associated areas included in this policy and support the issuance of a parking citation, if needed.
Data Retention
Data collected by the LPR system not resulting in parking enforcement action or other official university business is retained for 90 days. Data resulting in parking enforcement action is retained with the citation record according to established University data retention policies. Data associated with an ongoing law enforcement investigation shall be retained with the investigative record according to established University records and retention policies.
Access to LPR System
Access to the LPR system is restricted to trained University personnel performing their official University duties. All personnel with access to the system use unique identifiers and passwords to access records and all login activity, record additions, and other activity is logged. Access to the system by others is prohibited.
Knowing What LPR Data We Have About Your Vehicle
University students, faculty, and staff may request a report detailing what, if any, LPR data TS has on the vehicle(s) he/she has registered with TS. These requests may be made in person by presenting a University‐issued ID to Transportation Services.
Requests from vehicle owners not affiliated with the University (and who therefore do not have a University‐issued ID or email account) may be made by presenting TS with proof of ownership of the vehicle along with a valid photo ID, subject to restrictions imposed by applicable law, including but not limited to FERPA. Such requests, and all other external requests for records, will be handled on a case‐by‐case basis, in consultation with the University’s Assistant Attorney General’s Office.
USE OF WASHINGTON STATE DEPARTMENT OF LICENSING DATA
The University accesses the Washington State Department of Licensing (DOL) database to retrieve registered vehicle owner contact information to collect fines resulting from University parking citations.
Data Accessed
Only the name and address of registered vehicle owners are accessed and used for the purpose described above. This information is accessed by:
- A third party contracting with WWU to collect on outstanding parking citations on behalf of the University.
- Limited University personnel within the Transportation Services needing to contact a vehicle owner when the owner’s correct contact information is not available through Western’s parking portal database.
Data Retention
Each vehicle record (registered owner name and address) requested through the DOL system is available only at the time which the request is made. It is not stored by the University but is retained in a vendor’s system according to established University data retention policies.
Access to DOL system
Access to the DOL system is restricted to a very limited number of trained University personnel whose duties include citation collection duties. All personnel with access to the system use unique identifiers and passwords to access records and all login activity, record additions, and other activity is logged. Access to the system by others is prohibited. Third party access is held to the same standards per a data sharing agreement.