Per Civil Code section 1798.90.51(b), the following is the Sun Meadows usage and privacy policy for the onsite ALPR (Automatic License Plate Recognition) System:
1. Authorized Purposes for Using the ALPR System and Collecting ALPR Information:
The ALPR system will be used solely for enhancing the security and safety measures within the park premises. The authorized purposes include:
a. Monitoring and controlling access to the park for residents, guests, and authorized personnel.
b. Identifying and deterring criminal activities, such as theft, vandalism, and trespassing, within the park's common areas.
c. Assisting law enforcement in investigating and solving criminal incidents that occur within the park's vicinity.
d. Implementing traffic management and ensuring compliance with parking regulations for the convenience of residents and visitors.
2. Designation of Authorized Personnel and Training Requirements:
Only designated employees and independent contractors with specific job titles, such as the General Manager, Off-site Manager, and Independent Security Expert will be authorized to use or access the ALPR system and collect ALPR information. Prior to accessing the system, these individuals must undergo comprehensive training on the lawful and ethical use of the ALPR system, privacy protection, data security, and compliance with applicable laws and regulations.
3. Monitoring and Compliance with Privacy Laws:
The ALPR system will be continuously monitored to ensure the security and integrity of the collected information. To maintain compliance with privacy laws, access to the ALPR data will be restricted to authorized personnel only. Regular audits and reviews will be conducted to assess adherence to the policy and applicable privacy laws. Additionally, any potential data breaches or unauthorized access incidents will be promptly investigated and addressed.
4. Sale, Sharing, or Transfer of ALPR Information:
The ALPR information collected within the park premises will not be sold, shared, or transferred to any third-party entities for commercial or non-essential purposes. Exceptions may only occur when lawfully required by government authorities or law enforcement agencies for the investigation of criminal activities. In such cases, the release of information will be in compliance with relevant laws and regulations.
5. Official Custodian/Owner of the ALPR System:
The General Manager of the park or a designated high-level management official will be the official custodian and owner of the ALPR system. This individual will be responsible for overseeing the implementation, operation, and compliance with the ALPR policy.
6. Measures for Ensuring Accuracy and Correcting Data Errors:
The ALPR system will employ reasonable measures to ensure the accuracy of the collected data. Regular maintenance, calibration, and testing of the equipment will be carried out to minimize errors. In case of any identified data errors, a well-defined process will be in place to promptly correct the information and rectify any discrepancies.
7. Retention Period and Data Destruction Process:
ALPR information will be retained for a limited and necessary period. The retention period will be set to the minimum duration required for security and law enforcement purposes, with a maximum retention period of up to 60 days, consistent with general surveillance policy. After this period, the ALPR operator will ensure the secure and irreversible destruction of the retained ALPR information to safeguard the privacy of individuals.