This policy governs the Automated License Plate Recognition System (“ALPR system” or “system”) operated by Hunter Engineering Company (“Hunter”), and applies to our employees, customers, and camera affiliates who have access to or use our systems.
Our ALPR system is a searchable computerized database resulting from the operation of one or more fixed cameras associated with vehicle service or inspection equipment, combined with computer algorithms to read and convert images of registration plates and the characters they contain into computer-readable data.
The information contained in the system (“LPR data”) includes images of license plates, plus the date, time and location when the images were collected, and the license plate characters and numbers associated with the image. The images stored in the system are collected from areas visible to the public where there is no reasonable expectation of privacy.
The collection and dissemination of the information contained in the system is protected activity under the First Amendment to the US Constitution. Moreover, LPR data stored in our system does not include any personally identifying information (PII), or information which relates the license plate image to the driver or registered owner of a vehicle. PII contained in vehicle registration information is protected by federal law (Driver’s Privacy Protection Act, Title 18, US Code, Section 2721 et seq.) and state laws. Law enforcement and other users may have access to vehicle registration information, and other sources of PII, which they may correlate with LPR data stored in the system to create vehicle hotlists in accordance with the above referenced federal law.
(A) Use and Collection of LPR Data
Hunter Engineering Company authorizes collection of LPR data for the use of the Hunter and its customers consistent with this policy. The authorized uses of the ALPR system are:
By customers to identify or ascertain the make, model, and year of a specific vehicle under circumstances when there is a legitimate commercial interest, such as identifying a vehicle for purposes of recalling vehicle manufacturer specifications associated with the identified vehicle.
By Hunter to make LPR data available to customers for the purposes above, and to provide market research information to customers based on aggregated LPR data.
Examples of permitted users and uses of the system and data include:
Vehicle repair and inspection services companies and other businesses that have a legitimate commercial interest in identifying a vehicle for purposes of recalling manufacturer specifications or vehicle inspection and/or service records.
Entities to which information may be disclosed as a permissible use pursuant to Section 2721 of Title 18 of the United States Code.
Hunter Engineering Company does NOT make the ALPR system or data it contains available to individuals for personal, non-commercial purposes.
All employees of Hunter are authorized to use the ALPR system to demonstrate the system to customers, or potential customers, provide customer support, or collect data for purposes authorized by this policy. All independent contractors of Hunter are authorized to use the ALPR system for purposes consistent with their underlying contract with the company and this policy. All authorized employees and independent contractors that collect LPR data are required to read and understand any documents (e.g. the operational manual for the specific vehicle service or inspection system) necessary to successfully operate the associated vehicle service or inspection system.
(C) Accuracy of LPR Data
The collection of LPR data is automated so that the license plate images, and the details of when they are collected, are included in the system without review, along with the computer translation of the license plate number. Although very infrequent, the license plate translation is sometimes inaccurate or incomplete. To avoid mistaken use of LPR data Hunter recommends users of the data confirm the computer translation before taking any action as a result of LPR data. Hunter corrects mistaken translation and other database errors when identified.
Hunter Engineering Company retains LPR data as long as it has commercial value. Hunter periodically evaluates the use of historical LPR data to determine if the cost to maintain the data exceeds its value.