PCN Parallel Parking - No Reg No

Castle

poshMosh said:

Hi All,

I need some advise please:

My SAR request came back from Parallel Parking and they've advised that they can't provide the "Due to Data Protection I am unable to provide you with the machine data as this contains other customers vehicle registration numbers" . Now it should be noted that my ticket does not have the Reg No, but I have the actual identifier printed on the back. How can I respond to this?

The second element is they did not provide the pictures of my car (even though they sent this via the written PCN).

I look forward to your support.

Thanks,

Each ticket issued by a PDT should have an unique identification number; so the "identifier" is now your personal data as it can be linked to your VRM because you have told them that.

From the ICO website:-
https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/key-definitions/what-is-personal-data/

• Personal data only includes information relating to natural persons who:

• can be identified or who are identifiable, directly from the information in question; or

• who can be indirectly identified from that information in combination with other information.

So you need to ask for all data on this PDT ticket.

poshMosh

Jenni_D said:

Remind me - what was the alleged contravention here? Failure to pay? Failure to display?

Was the VRM required to be entered on the PDT machine at the car park?

Hi Jenni,

So this is failure to have the reg number on the ticket (even thought the PDT still issued a ticket). 

poshMosh

Castle said:

poshMosh said:

Hi All,

I need some advise please:

My SAR request came back from Parallel Parking and they've advised that they can't provide the "Due to Data Protection I am unable to provide you with the machine data as this contains other customers vehicle registration numbers" . Now it should be noted that my ticket does not have the Reg No, but I have the actual identifier printed on the back. How can I respond to this?

The second element is they did not provide the pictures of my car (even though they sent this via the written PCN).

I look forward to your support.

Thanks,

Each ticket issued by a PDT should have an unique identification number; so the "identifier" is now your personal data as it can be linked to your VRM because you have told them that.

From the ICO website:-
https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/key-definitions/what-is-personal-data/

• Personal data only includes information relating to natural persons who:

• can be identified or who are identifiable, directly from the information in question; or

• who can be indirectly identified from that information in combination with other information.

So you need to ask for all data on this PDT ticket.

This is really useful - thanks!

So effectively, I should respond with the above given I actually have the UID, the date, the fee and the PDT reference number itself:

"As the ticket contains the UID "xx" and PDT ID "xx", this is now my personal data as per the ICO's guidance linked below:

• Personal data only includes information relating to natural persons who:

• can be identified or who are identifiable, directly from the information in question; or

• who can be indirectly identified from that information in combination with other information.

Does the above response seem reasonable?

Many thanks,

Coupon-mad

Yes but you haven't said what you want them to do and by when.

poshMosh

Coupon-mad said:

Yes but you haven't said what you want them to do and by when.

Hey - I only provided a snippet of what my reply will be. Below is the full response including their first response:

*Parallel Parking*--------------------------------------------

Please see SARS as requested

Due to Data Protection I am unable to provide you with the machine data as this contains other customers vehicle registration numbers

*Parallel Parking*--------------------------------------------

*My Response*-----------------------------------------------------

Dear Sir, Madam,

Thank you for your response.

There seems to be a number of artefacts missing from your SAR attachment which I provided below:

1. All photos relating to vehicle x (Reg Number: XXXX XXX), given this was sent as part of the PCN, why hasn't this been attached?

2. With regards to to your Machine Data and data protection, you clearly have demonstrated limited understanding of the regulation (specifically GDPR). The ticket (which was purchased) has a unique identifier which I now own all related information associated to this ticket as per the ICO Guidance which I have provided key points below including the link: 

ICO's guidance linked below:

• Personal data only includes information relating to natural persons who:

• can be identified or who are identifiable, directly from the information in question; or

• who can be indirectly identified from that information in combination with other information.

Ticket Information: Machine Reference: xxxxxxx, UID: XX, Date: XX/XX/XX, Time: 00:00, Fee: 2.00, Re-order Quote: xxx-xxxxxx

Next Steps:

1. As per the ICO guidelines above, please send across all data relating to the ticket as per the evidence above (you do not need to send the whole machine record even though this does not contravene Data Protection / GDPR regulation). Specifically:
+A printout of the machine log with partially redacted tickets (Partial VRNs) so a cross reference of the unique identifier can be made against the ticket information provided in section 2 above. This will allow me to identify the ticket with the missing number plate to the redacted log provided. 
2. Please send across this information within 7 working days of this email letter (Close of Business 19/07/2022).
3. Email over all pictures of the vehicle in question within 7 working days of this email letter (Close of Business 19/07/2022).

Thank You,

Yours Faithfully,

X
*My Response*-----------------------------------------------------

If you can kindly review my response, that would be much appreciated.

Thanks!

Coupon-mad

 please send across the ticket.

They can't do that. And that isn't what you wanted.

Umkomaas

Dear Sir/Madam  ...  Yours faithfully. 

NOT 'Kind regards', they're trying to sue you for goodness sake!

poshMosh

Coupon-mad said:

 please send across the ticket.

They can't do that. And that isn't what you wanted.

Coupon-mad said:

 please send across the ticket.

They can't do that. And that isn't what you wanted.

I've made the tweak to send across all related data points to that UID rather than ask them to send across the ticket (even though there's actually no reg number on it)

I've made the tweak to send across all related data points to that UID rather than ask them to send across the ticket (even though there's actually no reg number on it). Also amended the signature - completely forgot to amend.

poshMosh

before I hit send, does the updated response reflect the suggested changes?

Coupon-mad

You need to spell out and explain exactly what you want.

A partially redacted machine log so that partial VRM entries can be seen (not full) in order to find the payment matched to a typo/near miss of this numberplate or to discount that possibility.