ALPR Policy

AUTOMATED LICENSE PLATE RECOGNITION (ALPR) USAGE AND PRIVACY POLICY

G&I XI Fig Garden Village Propco, LP (“Owner”) utilizes automated license plate recognition (“ALPR”) technology at the Fig Garden Village shopping center (the “Center”).

A. Purpose

ALPR information may be collected, accessed, and used to:

Investigate damage to Center property;

Address emergency situations; and

Assist law enforcement in responding to threats to public safety. 

B. Access and Use of the ALPR System(s)

The following parties are authorized to collect, access, and use the ALPR system(s) or ALPR information:

General Manager and Operations Manager of the Center, who manage Center operations, including parking and the ALPR system(s); 

Universal Protection Service, LP doing business as Allied Universal Security Services (“Allied”) Personnel, specifically the Security Director and Assistant Security Director, who assist with Center security services and investigations; and

Net Me In Pro Inc. (“Net Me”) Personnel, specifically the Owner and Operations Director, who provide technology support services for the ALPR system(s).

All personnel with access to ALPR information undergo training on the operation and proper use of the ALPR system(s) prior to being provided access to the ALPR system(s).

C. System Monitoring

Owner, Allied, and Net Me use administrative, operational, technical, and physical safeguards to protect the ALPR system(s) and ALPR data from unauthorized access, use, destruction, modification, or disclosure. These measures include unique username(s) and password(s) and user training. 

D. Information Sharing

Owner and the authorized users identified above do not sell ALPR information. They do not share ALPR information except for the purposes stated above or as obligated by law, such as by search warrant or subpoena. 

E. Official Custodian

The official custodian of the ALPR information is the Center General Manager. For additional information please contact the Center General Manager at jhansen@centercal.com. 

F. Data Accuracy

Reasonable technical measures, including regular testing and maintenance, are utilized in order to ensure the accuracy of the ALPR information. Such reasonable measures include monitoring in case of license plate reading failures and annual preventative maintenance. 

G. Data Retention

ALPR information is retained for a period of approximately 30 to 60 days and is automatically overwritten and deleted when the ALPR system(s) storage is at capacity. This retention period may be increased due to legal obligations. Examples of legal obligations include administrative or judicial proceedings, such as search warrants, subpoenas, and litigation. Any ALPR information retained as a result of legal obligations will be destroyed once the legal obligation to retain it ends.

H. Changes to this Policy

This ALPR Usage and Privacy Policy may be revised from time to time by Owner. Any changes to this policy will take effect upon posting.