CCTV Policy
WILSON PARKING NEW ZEALAND LIMITED
CCTV and Image Request Policy
1 Details of this CCTV and Image Request Policy
1.1 This CCTV and Image Request Policy (Policy) sets out how Wilson Parking New Zealand Limited (Wilson) operates and manages CCTV and licence plate recognition systems, and how Wilson will collect and handle the information from these systems (Surveillance Systems).
1.2 CCTV or 'Closed Circuit Television' refers to camera surveillance systems that capture images and/or videos of individuals, or information relating to individuals. Licence plate recognition refers to technology that captures photographic images and/or videos from vehicle licence plates (Surveillance Devices).
1.3 This Policy applies to all Surveillance Systems and Devices used, owned, operated, or otherwise managed by Wilson and the resulting Personal Information collected from these Surveillance Systems and Devices.
1.4 When we refer to personal information in this Policy, we mean personal information as defined in the Privacy Act 2020 (Privacy Act), which is any information about an identifiable individual (Personal Information).
1.5 This Policy should be read in conjunction with our Privacy Policy (Wilson Privacy Policy), which you can access [here]1.
1.6 We will not use or share Personal Information that we collect through Surveillance Systems and Devices, except as set out in this Policy and the Wilson Privacy Policy, neither of which limit or exclude any of your rights under the Privacy Act.
2 Purposes of operating Surveillance Systems and Devices
2.1 Wilson may operate Surveillance Systems and Devices for any of our business purposes, and for directly related purposes, including, but not limited to:
2.1.1 monitoring the security of our car parking facilities;
2.1.2 monitoring the security and safety of Wilson-owned and/or operated property and premises;
2.1.3 monitoring the security and safety of Wilson employees;
2.1.4 monitoring the security and safety of you and your property;
2.1.5 monitoring compliance of the terms and conditions of our carparking facilities;
2.1.6 verifying the details of your vehicle;
2.1.7 verifying that payment has been made for the provision of our services;
2.1.8 providing operational information at, or in the vicinity of, a Wilson-owned or operated property and premises, in relation to Wilson's business;
2.1.9 providing optimised efficiency and customer service; and
2.1.10 enhancing data gathering capabilities for our workforce and vehicle management.
3 Collection of Personal Information from Surveillance Systems and Devices
3.1 When you use, access, or otherwise visit a Wilson-owned or operated property or premises, we may collect your Personal Information from Surveillance Systems and Devices that we operate.
3.2 This Personal Information may include images and videos of you and your vehicle, including your car licence plate details (Footage).
3.3 By using, accessing, or otherwise visiting a Wilson-owned or operated property or premises, you agree to Footage being collected by Surveillance Systems and Devices under the control of Wilson. Wherever practicable, appropriate notification and/or signage will be in place to notify you that our Surveillance Systems and Devices are in place and operating.
3.4 Surveillance Systems and Devices generally operate 24 hours a day, seven days a week at most Wilson-owned or operated premises and property.
3.5 Wilson strives to maintain the optimal functioning of its surveillance systems. It cannot provide an assurance against unforeseen technical issues or vandalism that may hinder access to the requested Footage.
4 Security and retention of Footage
4.1 Footage collected by Surveillance Systems and Devices is stored by Wilson on a secure platform. Appropriate security measures are taken to protect Footage against loss, unauthorised access to, disclosure, alteration, or destruction.
4.2 Footage will be stored for a minimum of thirty (30) days and a maximum of ninety (90) days, after which it will be securely disposed of, unless the Footage is being used for one or more of the purposes outlined in this Policy.
5 Disclosure of and access to Footage
Wilson Employees
5.1 Wilson has a dedicated ParkWatch team tasked with operating and controlling Surveillance Systems and Devices.
5.2 Within this ParkWatch team, only authorised Wilson employees, consultants or contractors have access to Surveillance Systems and Footage. From time to time, or following a security, health and safety, or operational event, other Wilson employees may be permitted to access and view Footage, if the Footage is relevant to their role and in accordance with the purpose(s) for operating the Surveillance Systems.
Third Parties
5.3 Footage relating to criminal activity or potential criminal activity at Wilson-owned or operated property and premises may be referred to the New Zealand Police or other relevant authorities as required for their use.
5.4 From time to time, Wilson may also receive requests for Footage from third parties, which may include the New Zealand Police and other public sector agencies.
5.5 Footage may be disclosed to third parties if:
5.5.1 the disclosure is necessary for court or tribunal proceedings;
5.5.2 the disclosure is necessary to enable a public sector agency to uphold the law (including allowing a public sector agency to prevent, detect, investigate, prosecute, and punish offences);
5.5.3 the disclosure is necessary to prevent or lessen a serious or imminent threat to public health and safety or the life and health of an individual;
5.5.4 the individual has consented to the use or disclosure; or
5.5.5 the disclosure is otherwise permitted by law.
5.6 Any request for Personal Information captured by Surveillance Systems by a third party will be reviewed by the Privacy Officer before releasing any Footage. The release of Footage to third parties will be managed in accordance with this Policy, the Wilson Privacy Policy, the Privacy Act, and any other relevant legislation that may be applicable due to the nature of the third-party requestor.
Individuals
5.7 Under the Privacy Act, you have the right to access and correct Personal Information that is held by Wilson, which is subject to certain grounds of refusal in the Privacy Act.
5.8 Any request made by an individual to access Footage must be made by completing and sending an Individual Access Request form to privacy@wilsonparking.co.nz. This Individual Access Request Form can be found [here]2.
5.9 We will consider and respond to your request in accordance with the Privacy Act.
5.10 When deciding whether to grant access to Footage, we will consider a variety of factors including whether the Footage is readily retrievable if there are other individuals in the Footage, the reason(s) for requesting the Footage, and any other circumstances that we consider relevant in accordance with the Privacy Act.
5.11 We may also request proof of identity from you prior to granting access to any Footage, to ensure that you are the individual concerned.
6 Changes to this Policy
6.1 We may update this Policy from time to time. We will notify you of any such updates by publishing the updated Policy on our Website. The revised Policy will apply from the date that we upload it to the Website.
6.2 We encourage you to review this Policy periodically on our website, along with the Wilson Privacy Policy, to stay informed about how Wilson is collecting and handling your Personal Information.
7 Contact and complaints
7.1 Please contact us at privacy@wilsonparking.co.nz if you have any questions, concerns, or complaints in relation to this Policy or the protection of your Personal Information. Our Privacy Officer will investigate and respond to any complaints or concerns as soon as possible and in accordance with the time frames and procedures set out in the Privacy Act.
7.2 If you are not satisfied with how we have handled your complaint, you can complain to the Office of the Privacy Commissioner.