GEMINI PARKING SOLUTIONS
In this policy, ‘Gemini’, ‘our’, ‘us’ and ‘we’ are used throughout to refer to Gemini Parking Solutions London Ltd.
Gemini Parking Solutions London Ltd is a subsidiary of the APCOA Parking Group of companies in the UK, of which APCOA Parking (UK) Limited is the main operating company.
Gemini takes its obligations about your personal information seriously and is committed to ensuring your personal data is protected. This privacy notice describes how Gemini, in its various roles as both a Controller and Processor, collects, uses and protects your information. Gemini is registered with the Information Commissioner’s Office (ICO).
How we collect your information
The information we hold about you comes from the way you engage with us such as through your participation and contribution in Gemini related activities, taking part in customer research and surveys or product trials. We also collect your personal data if you enquire about our services through our websites, when purchasing, registering or subscribing to a Gemini service or product, or become one of our business partners. We may collect information about you through our website, through our product applications, via email, the post, over the phone, via Webchat or from discussions with you or from information received from you relating to car park bookings, Parking Charge Notice (PCN) payments, a season ticket, parking permits our provision of a Car Park Management Services or other services to our clients or when applying for a Gemini advertised vacancy.
We may also collect details of your visits to our website, including traffic data, location data, weblogs and other communication data and the resources that you access.
The type of information we hold
The information we hold may include name, address, contact telephone numbers, email addresses, business name, twitter, Facebook and LinkedIn account, vehicle registration mark (VRM), ANPR and CCTV related images of your vehicle, credit card details, bank details and transaction history. In some cases, we may also hold special category data (sensitive data).
How we use your information
We lawfully process your information to fulfil the contract we have with you (for example of your car space booking or use), to allow you to benefit from offers we have available, as a business partner, or as a potential employee, and to enforce non-compliance of our car parking Terms & Conditions. We use your information in the following ways:
- To provide you with the information or service you have requested.
- To process your payments
- To process a job application
- To process car parking permits
- To process a Parking Charge Notice
- To create an account
- Where you have not opted-out, we will use your information for the legitimate business interest of sending you information about other Gemini products and services, but we will always offer you the right to opt-out of future communications
Who we will share your information with
We will not sell or share personal information about you with third parties without your consent unless the law allows us to. We are required by law, to pass on some of your personal data to:
- The DVLA to request details of the registered keeper of the vehicle in order to enforce non-compliance of our car parking Terms & Conditions
- Third parties such as, Parking on Private Land Appeals service (POPLA) at your request, and Debt Collection Agencies, Bailiffs and Courts in relation to unpaid Parking Charge Notices.
- Our service providers who manage some of our Marketing, Car park bookings, the processing of our Parking Charge Notices, Web services and Group Procurement scheme
- Business partners where we need to exchange the information to fulfil a parking contract arranged through them or through Gemini
- Law Enforcement Agencies in circumstances where we have reason to think a criminal act may have been committed
Our third-party providers are bound by UK privacy law and the terms of the contracts we have with them.
Camera Monitoring Privacy Notice
Gemini currently uses CCTV cameras and other camera related surveillance systems such as ANPR and body worn cameras to view and record individuals or vehicles on and around our premises and the areas we have agreed to manage for our clients. In this Notice we will refer to the CCTV, ANPR and other camera related surveillance systems collectively as ‘Camera Monitoring’ This Notice outlines why we use Camera Monitoring, how we will use that data and how we will process data recorded by such devices to ensure we are compliant with data protection law and best practice. This Notice also explains how to make a Subject Access Request in respect of personal data created by Camera Monitoring.
Reasons for the use of Camera Monitoring
We currently use Camera Monitoring in and around our premises and the areas we have agreed to manage for our clients as outlined below. We believe that such use is necessary for legitimate business purposes, including:
- to prevent crime and protect buildings and assets from damage, disruption, vandalism and other malicious acts
- for the personal safety of staff, visitors and other members of the public and to act as a deterrent against crime including fraud;
- to support law enforcement bodies in the prevention, detection and prosecution of crime;
- to assist in ensuring the health and safety of staff and others
This list is not exhaustive and other purposes may be or may become relevant.
Images are only viewed by authorised personnel. All staff using Camera Monitoring are given appropriate training to ensure they understand and observe the legal requirements related to the processing of the data that has been collected.
How we use data gathered by Camera Related Surveillance Systems
In order to ensure that the rights of individuals recorded by our Camera Monitoring are protected, we will ensure that data gathered is stored in a way that maintains its integrity and security.
Given the large amount of data generated by Camera Monitoring, we may store video footage using a cloud computing system. We will take all reasonable steps to ensure that any cloud service provider maintain the security of our information, in accordance with industry standards.
Where we engage data processors to process data on our behalf, we ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.
Disclosure of Data Gathered by Camera Monitoring
We may share data with our group companies and other associated companies or organisations, for example, our clients and/or shared services partners where we consider that this reasonably necessary for any other the legitimate purposes set out above.
No images from our Camera Monitoring will be disclosed to any other third party, without express permission being given by our Data Protection Officer (DPO). Data will not normally be released unless satisfactory evidence that it is required for legal proceedings or under a court order has been produced. In other appropriate circumstances, we may allow law enforcement agencies to view copy or remove the data where this is required in the detection or prosecution of crime.
We will maintain a record of all disclosures of such data. No images from our Camera Monitoring will ever be posted online or disclosed to the media.
Privacy Notice – General Information
Certain information applies to both sections of the Privacy Notice and these matters are dealt with here.
Retention and Storage of your information
We will retain your personal information in accordance with legal and regulatory requirements. We will only retain your information while we are actively engaged with you. Where we have had no interaction with for a period of 6 years, will delete your data. We will also delete personal information after a period of 6 years for related contracts that have been inactive.
In respect of job applications, a successful candidate will be given information about retention periods once appointed; unsuccessful applicants will be given the option to allow their information to retained should similar opportunities arise in the following 12 months and if not it will be deleted 6 months after the end of the relevant recruitment process.
Data from Camera Monitoring will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained will vary according to the purpose for which they are being recorded. For example, where images are being recorded for crime prevention purposes, data will be kept only long enough for incidents to come to light. Where the images are being used to regulate and enforce parking conditions, the images will be retained until any parking charge has been settled. In all other cases, recorded images will be kept for no longer than 30 days. The Site Manager or designated senior employee will maintain a log of when data is deleted.
At the end of their useful life and in accordance with our retention policy, all images stored in whatever format will be erased permanently and securely. Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs and hard copy prints will be disposed of as confidential waste.
Your personal information will be stored on systems owned or operated by Gemini or those of our specific suppliers and will only be stored inside the European Economic Area (EEA), or a country approved by the EU. You should be aware, however, that where payments are made using credit or debit card transactions, those payments are governed by the terms of your agreement with your card issuer.
Within Gemini, your information will be stored on our secured systems in accordance with Gemini’s Information Security Policy.
You have the right to:
- object to processing of personal data that is likely to cause you, or is causing you, damage or distress;
- have inaccurate personal data about you rectified.
- request your information be deleted or destroyed and if we can we will, but sometimes we must maintain some records for legal reasons
If you are not happy how we are using your information or how we have responded to your request, you have the right to complain to the Information Commissioner’s Office at www.ico.org.co.uk.
Requests to prevent processing
We recognise that, in rare circumstances, individuals may have a legal right to prevent processing likely to cause substantial and unwarranted damage. For further information regarding this, please contact the Data Protection Officer at DPO@geminiparkingsolutions.com .
How we will tell you about future changes to this privacy notice
Any changes we make to our privacy notice will be put on our website. Please check for updates from time to time so you are always fully aware of what information is collected and how it is used.
How you can access your information
You have the right to request access the information we hold about you. To make a request for your personal information, please contact the Data Protection Officer at DPO@geminiparkingsolutions.com .
In respect of Camera Monitoring data, please note that we reserve the right to obscure images or mute sounds of third parties when disclosing such data as part of a subject access request, where we consider it necessary to do so to protect the rights of others.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact the Data Protection Officer at DPO@geminiparkingsolutions.com .
Last updated January 1st 2023.