Automated License Plate Recognition (ALPR) Usage And Privacy Policy At San Clemente

The Outlets at San Clemente uses Automated License Plate Recognition (“ALPR”) technology, which consists of a system of cameras and associated software that capture license plate images and process those images into computer-readable data (“ALPR System”).  Outlets at San Clemente’s ALPR System is installed at 101 West Avenida Vista Hermosa, San Clemente, California 92672.  This policy can be reviewed in writing at any location where Outlets at San Clemente’s ALPR Systems are installed, and on Outlets at San Clemente’s website, located at https://www.outletsatsanclemente.com

Outlets at San Clemente may update this policy at any time. If we make material changes to this policy, we will use reasonable efforts to notify you in accordance with applicable laws.  

DATA COLLECTION

The following data may be collected using Outlets at San Clemente’s ALPR System (collectively, “ALPR Data”):

• License plate numbers and license plate state;
• Video recordings of vehicles and occupants of the vehicles (and surroundings); and
• Date, time, and geographic location associated with each of the categories of data listed above.

PURPOSE

ALPR Data may be accessed and used for the following purposes:

• To enhance public safety and security, including by investigating incidents such as theft, vandalism, or trespassing;
• To manage parking operations and enforce parking policies;
• To identify stolen vehicles and report them to law enforcement; and
• To cooperate with law enforcement agencies, government requests, subpoenas, court orders, or valid legal process.

AUTHORIZED PARTIES

Outlets at San Clemente’s ALPR System and ALPR Data is led by Outlets at San Clemente’s Security Managers, and Outlets at San Clemente’s Security Officers are also authorized to use and/or access Outlets at San Clemente’s ALPR System and ALPR Data (collectively, “Authorized Users”). Only Authorized Users are permitted to access Outlets at San Clemente’s ALPR System and ALPR Data.

Authorized Users are required to complete privacy and information security training before they may access ALPR Data, which addresses the responsible and ethical use and handling of ALPR Data to protect privacy interests and comply with applicable laws.  The training includes understanding the underlying principles of data privacy, the protection of personal information, compliance with applicable laws and regulations, and how to respond to security incidents and requests to access ALPR Data.

DATA RETENTION

ALPR Data is retained for 60 days, except as required to comply with legal obligations, in connection with active investigations, or in connection with managing parking operations and enforcing parking policies. After the retention period expires, we take steps to securely delete or anonymize the ALPR Data.

DATA SHARING

Outlets at San Clemente does not sell, lease, or otherwise commercially distribute ALPR Data. ALPR Data may be shared with third parties in limited circumstances, including:

• To law enforcement or other governmental authorities, in order to cooperate with government requests, subpoenas, court orders, or valid other legal process.
• With our service providers, Vigilant and Advanced Security Systems Integration, which provides and supports our ALPR technology, subject to the confidentiality agreement between us.
• To third parties in connection with or anticipation of an asset sale, merger, bankruptcy, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of all or some of our assets; or as needed support for external auditing, compliance, legal, and corporate governance functions.

In the limited instances in which ALPR Data may be shared with third parties, Outlets at San Clemente ensures that all transfers are made pursuant to a valid agreement or legal process, including any government request, subpoena or court order. All transfers of ALPR Data are made using secure means.

DATA SECURITY

Outlets at San Clemente implements reasonable security measures designed to protect ALPR Data, including:

• Secure, closed storage;
• Network and system access controls; and
• Monitoring for unauthorized access to ALPR Data.

Outlets at San Clemente also maintains a record log of access requests to the ALPR System to ensure  ALPR Data is collected, accessed and used in compliance with Outlets at San Clemente procedures and applicable laws.

DATA ACCURACY AND CORRECTION

Outlets at San Clemente regularly reviews ALPR Data for to ensure that cameras are angled correctly and visibility is good. When Outlets at San Clemente’s ALPR System returns a match to a stolen vehicle, wanted person, or other database that license plate information is queried against, it is referred to as a “hit.” If a “hit” on a vehicle license plate occurs, the Dispatch Officer shall confirm and verify that the ALPR Data is accurate and not a misread by comparing the video footage with the ALPR Data.

Any concerns regarding the accuracy of ALPR Data may be submitted using the contact information below.

OFFICIAL CUSTODIAN

The official custodian of ALPR Data and Outlets at San Clemente’s ALPR System is Outlet at San Clemente’s Security Manager.

CONTACT INFORMATION

For questions or concerns about this policy or any concerns regarding the accuracy of ALPR Data, please contact the Security Manager on duty at 949-378-8293.