Automated License Plate Recognition (ALPR) Usage And Privacy Policy Citadel Outlets

Citadel Outlets uses Automated License Plate Recognition (“ALPR”) technology, which consists of a system of cameras and associated software that capture license plate images and process those images into computer-readable data (“ALPR System”). Citadel Outlets’ ALPR System is installed at 100 Citadel Drive, Los Angeles, California 90040. This policy can be reviewed in writing at any location where Citadel Outlets’ ALPR Systems are installed, and on the Citadel Outlets’ website, located at https://www.citadeloutlets.com

Citadel Outlets may update this policy at any time. If we make material changes to this policy, we will use reasonable efforts to notify you in accordance with applicable laws. 

DATA COLLECTION

The following data may be collected using Citadel Outlets’ ALPR System (collectively, “ALPR Data”):

•  License plate numbers and license plate state;
•  Video recordings of vehicles and occupants of the vehicles (and surroundings); and
•  Date, time, and geographic location associated with each of the categories of data listed above.

PURPOSE

ALPR Data may be accessed and used for the following purposes:

•  To enhance public safety and security, including by investigating incidents such as theft, vandalism, or trespassing;
•  To manage parking operations and enforce parking policies;
•  To identify stolen vehicles and report them to law enforcement; and
•  To cooperate with law enforcement agencies, government requests, subpoenas, court orders, or valid legal process.

AUTHORIZED PARTIES

Citadel Outlets’ ALPR System and ALPR Data is led by Citadel Outlets’ Dispatch Managers, and Citadel Outlets’ Dispatch Officers are also authorized to use and/or access Citadel Outlets’ ALPR System and ALPR Data (collectively, “Authorized Users”). Only Authorized Users are permitted to access Citadel Outlets’ ALPR System and ALPR Data.

Authorized Users are required to complete privacy and information security training before they may access ALPR Data, which addresses the responsible and ethical use and handling of ALPR Data to protect privacy interests and comply with applicable laws. The training includes understanding the underlying principles of data privacy, the protection of personal information, compliance with applicable laws and regulations, and how to respond to security incidents and requests to access ALPR Data.

DATA RETENTION

ALPR Data is retained for 60 days, except as required to comply with legal obligations, in connection with active investigations, or in connection with managing parking operations and enforcing parking policies. After the retention period expires, we take steps to securely delete or anonymize the ALPR Data.

DATA SHARING

Citadel Outlets does not sell, lease, or otherwise commercially distribute ALPR Data. ALPR Data may be shared with third parties in limited circumstances, including:

•  To law enforcement or other governmental authorities, in order to cooperate with government requests, subpoenas, court orders, or valid other legal process.
•  With our service providers, Vigilant and Secure Site Solutions, which provides and supports our ALPR technology, subject to the confidentiality agreement between us.
•  To third parties in connection with or anticipation of an asset sale, merger, bankruptcy, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of all or some of our assets; or as needed support for external auditing, compliance, legal, and corporate governance functions.

In the limited instances in which ALPR Data may be shared with third parties, Citadel Outlets ensures that all transfers are made pursuant to a valid agreement or legal process, including any government request, subpoena or court order. All transfers of ALPR Data are made using secure means.

DATA SECURITY

Citadel Outlets implements reasonable security measures designed to protect ALPR Data, including:

•   Secure, closed storage;
•   Network and system access controls; and
•   Monitoring for unauthorized access to ALPR Data.

Citadel Outlets also maintains a record log of access requests to the ALPR System to ensure ALPR Data is collected, accessed and used in compliance with Citadel Outlets procedures and applicable laws.

DATA ACCURACY AND CORRECTION

Citadel Outlets regularly reviews ALPR Data for to ensure that cameras are angled correctly and visibility is good. When Citadel Outlet’s ALPR System returns a match to a stolen vehicle, wanted person, or other database that license plate information is queried against, it is referred to as a “hit.” If a “hit” on a vehicle license plate occurs, the Dispatch Officer shall confirm and verify that the ALPR Data is accurate and not a misread.

Any concerns regarding the accuracy of ALPR Data may be submitted using the contact information below.

OFFICIAL CUSTODIAN

The official custodian of ALPR Data and Citadel Outlet’s ALPR System is Citadel Outlet’s Dispatch Manager.

CONTACT INFORMATION

For questions or concerns about this policy or any concerns regarding the accuracy of ALPR Data, please contact the Dispatch Manager on duty at 323-887-3473.