Automated License Plate Recognition (ALPR) Usage and Privacy Policy

12/23/2016

Irvine Company LLC and its affiliates (collectively, “Irvine”) or its contractors collect data through the operation of automated license plate readers at one or more Irvine locations. When in operation, these readers may automatically collect information from license plates, as well as record the location/date/time the information is collected ("ALPR Information"). Encrypted ALPR Information is transmitted to a searchable database of information from multiple sources ("ALPR System") operated by Vigilant Solutions, LLC ("ALPR Operator").

A. Access and Use of the ALPR System

Irvine is committed to limiting the access and use of ALPR Information in a manner that is consistent with respect for individuals' privacy and civil liberties. Accordingly, contractors used to collect ALPR Information on Irvine's behalf and Irvine employees are not authorized to access or use the ALPR Information or ALPR System. 

The ALPR Operator controls the ALPR System, and may access and use the ALPR System for any of the following purposes:  (i) to provide ALPR Information to law enforcement agencies (e.g., for identifying stolen vehicles, locating suspected criminals or witnesses, etc.);  or (ii) to cooperate with law enforcement agencies, government requests, subpoenas, court orders or legal process.

The ALPR Operator also allows law enforcement agencies to access the ALPR System directly for the purposes indicated in the law enforcement agency's applicable policies.

B. Authorized ALPR System Users and Required Training

Contractors used to collect ALPR Information on Irvine's behalf and any Irvine employees that collect ALPR Information undergo training regarding the requirements of this ALPR Usage and Privacy Policy. 

C. Monitoring of the ALPR Information and ALPR System

Irvine monitors use of the automated license plate readers to confirm that the ALPR Information is collected and transmitted to the ALPR Operator, and is not retained by Irvine following transmission to the ALPR Operator.  The ALPR Operator has advised Irvine that it maintains usage logs concerning the ALPR System, which track information such as when information in the ALPR System is accessed, the IP address and username accessing ALPR Information, and queries made when using the ALPR System, among other things. The ALPR Operator may audit such records from time to time.

D. Sale, Sharing or Transfer of ALPR Information

Irvine will not sell ALPR Information to third parties. ALPR information may be shared with or transferred to the ALPR System operated by the ALPR Operator.

E. Custodian/Owner of ALPR Information

The following entity is the official custodian and owner of the ALPR Information prior to it being transferred to the ALPR System and is responsible for implementing this ALPR Usage and Privacy Policy:

Irvine Company, LLC
550 Newport Center Drive
Newport Beach, CA 92658-6370

The following entity is the official custodian and owner of the ALPR System and, once the ALPR Information is transferred to the ALPR System, the following entity is also the custodian of the ALPR Information:

Vigilant Solutions, LLC
2021 Las Positas Court, Suite #101
Livermore, CA 94551

Vigilant Solutions' LPR Usage and Privacy Policy is available at vigilantsolutions.com/lpr-usage-privacy-policy.

F. Accuracy of ALPR Information

Irvine believes that the ALPR Information it collects is accurate, but does not check its accuracy.  The ALPR Operator has advised Irvine that it takes reasonable measures to ensure the accuracy of the ALPR Information, to correct for data errors, and to use tools to monitor and improve performance of the ALPR System.

​G. Retention and Deletion of ALPR Information

The automatic license plate readers used by Irvine or its contractors are programmed to transmit the ALPR Information to the ALPR System upon collection, at which point the ALPR Information is deleted from the automated license plate readers and is no longer in Irvine's possession. Should any ALPR Information not be deleted in accordance with the preceding sentence, such ALPR Information will be deleted as soon as commercially reasonable after Irvine discovers same. Information that is transmitted to the ALPR System will be retained and deleted in accordance with the retention policy implemented by the ALPR Operator or the law enforcement agency that may obtain the ALPR Information through access to the ALPR System.

H. Changes to this ALPR Usage and Privacy Policy

This ALPR Usage and Privacy Policy may be revised from time to time. Any changes to this ALPR Usage and Privacy Policy will take effect upon posting, and will apply to all ALPR Information regardless  of when collected, to the extent permitted by applicable law.

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