Saturday, 18 June 2011

Workplace Parking Levy to Use Auto Number Plate Recognition

Firstly, I should say that I support the principle of the workplace parking levy. I do believe that we need to reduce car use whenever possible and especially short journeys which cause the most environmental damage. This can really only be done by some form of 'green taxation' i.e a means to translate some of the external costs of car driving i.e. pollution etc into a financial cost to car users and the revenue from that used to invest in alternatives i.e. more public transport. In addition, it will be useful to be able to compare the effectiveness of WPL schemes compared to congestion charging and I suspect that this fact is a significant reason for the WPL to be still going ahead despite the change in government since the scheme was first approved.

However, I may have been naive but I had largely misunderstood how the scheme was to be operated. I presumed that businesses would apply for their car park license by saying how many spaces they had and a bloke from NCC would turn up with his tape measure and check. No, it's not as simple as that.

You see, the WPL Order set before parliament says that spaces provided for people visiting the premises but who don't work there or spaces for delivery vehicles and spaces used by blue badge holders aren't charged although must be declared for the license. Therefore employers are expected to work out how many parking spaces are provided for people who normally work there. Of course this has to be checked at some stage to ensure that employers don't suddenly sprout a huge number of disabled employees, or find that they need an awful lot of deliveries. And it seems that this checking is to be done by an ANPR equipped vehicle, which has just been ordered for the princely sum of £93k, including software.

I have concerns about ANPR, mainly around how the information is used and who it is passed onto. There are stories of it being used to identify protesters traveling by car to demos and it arguably requires proper authorisation under the Regulation of Investigatory Powers Act. I can't see any mention of the use of ANPR in any of the documents on the WPL page of NCC's website (although I haven't read all of them I must admit) and it doesn't seem to have come up in the public enquiry or any of the consultation documents. If anybody knows where there is any previous discussion on this or has any info on compliance (or not) with RIPA please let me know in the comments.

And this is a big issue because as far as I can see the method of monitoring is to drive the ANPR car into the employers' car parks and record the registrations of all the cars parked there. This is done 8 times in a 28 day period and the data analysed to identify the regular parkers.

So unlike the normal use of ANPR which is to monitor car use on the roads, which are in fact highly regulated public spaces, and merely produce data identifying when a person momentarily passes a fixed point*, it will be used to monitor private spaces and will collect data which could establish where an individual spends an awful lot of their time or whether a person is disabled (which is actually sensitive data under the Data Protection Act and thus requires explicit permission to record).

It doesn't take a lot of imagination to work out a whole list of agencies who would dearly love to get their hands on this info from the police to the social security agencies. It really is a whole new order of surveillance.

*Yes, I realise that a network of ANPR can build up a detailed picture of a person's traveling habits but the fact remains that the roads are public and there are good reasons for regulating car use. I'm not saying there aren't valid objections, merely that routine surveillance by the state of private spaces where individuals are staying is a big step up.


edjimf said...

They are assuming that they can get access to the car park in question. A lot of organisations might not be too happy about letting 3rd parties wander round their (barrier secured) car park.

Also what's to stop me taking my number plate of my car when I park? As I'm on private land I don't have to display it...

And another thing (!), what about shared car parks? The organisation I work for has a car park shared with other tenants on the site, how they going to get round that?

I'm not overly bothered personally by the WPL, I ride a motorbike so it doesn't affect me!

Andy said...

It will actually be a criminal offence to obstruct officers doing the survey.

With that in mind, the question of whether the ANPR plans were mentioned during consultation is ever more pertinent.

Not sure what they could do about removing number plates, maybe it would come under the obstruction measure?