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No Privacy Notice / ICO Registration at Site

Any organisation operating CCTV or ANPR on a car park must be registered with the ICO (if required to be) and must display a clear privacy notice at the site (typically on signage) informing visitors of the CCTV operation, the data controller's identity, and their rights. Failure to display adequate privacy information or to register with the ICO undermines lawful processing of data and provides grounds for an ICO complaint.

Legal basis

UK GDPR Articles 13 (information to be provided at collection), 5(1)(a) (lawful, fair and transparent processing); Data Protection (Charges and Information) Regulations 2018

How to identify this in your case

Visit the site or check photographs. Look for a privacy notice on the parking signs or separate notices. A legitimate notice will identify the data controller, state the purpose of processing, and provide ICO registration details. Check the ICO register to confirm the operator is registered. Challenge if absent.

Sample appeal wording

Dear [Operator / ICO], Re: GDPR Article 13 Breach — Car Park CCTV/ANPR at [LOCATION] [TO OPERATOR:] I write to notify you that the car park at [LOCATION] did not, on [DATE], display an adequate privacy notice as required by UK GDPR Article 13. The signage did not identify the data controller, the purposes of CCTV/ANPR processing, or the rights available to data subjects. This failure means that personal data (vehicle images and keeper records) was collected without providing the transparency information required by law. I have filed a complaint with the ICO (reference [if available]) and request that the PCN [NUMBER] be cancelled as part of resolution. [TO ICO:] I write to report a failure by [OPERATOR NAME] to display adequate privacy notices at a car park located at [ADDRESS]. I visited on [DATE] and attach photographs confirming the absence of any GDPR-compliant privacy notice on the parking signage. Yours faithfully, [NAME]

Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.

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Sources

  • UK GDPR Articles 5(1)(a) and 13
  • ICO CCTV guidance: https://ico.org.uk/for-organisations/guide-to-data-protection/key-dp-themes/surveillance

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