License Plate Recognition Data Privacy Policy

Purpose

This operating policy and procedure provides guidelines for the collection, retention and privacy of license plate recognition data at Central Michigan University.

General

Central Michigan University (CMU) uses license plate recognition (LPR) technology to manage parking on campus and enhance campus safety. CMU uses vehicle‐mounted systems, fixed camera installations and/or handheld devices to collect LPR data. CMU Police/Parking Services personnel shall be properly trained prior to using LPR equipment.

By using CMU’s Parking website (including its parking permit management portal) and participating in parking permit programs, customers acknowledge and accept the practices and policies outlined in this document.

Data collected

The LPR system captures up to two images of observed vehicles when a license plate is detected: a context image of the vehicle and its immediate surroundings, and an image of the license plate. Images taken are not of a resolution that allows for the identification of vehicle occupants, if any.

Along with the images, the LPR system also records the global positioning system coordinates and date/time information of the observation. Further software processing of the license plate image generates an alphanumeric version of the license plate number which is also stored with the record. The alphanumeric version of the license plate, date, time, and GPS information is referred to as metadata. The LPR system itself does not contain individual parking patron’s account information but may be linked to such information by CMU Parking Services.

Use of data

CMU Parking Services uses LPR data primarily for the purpose of parking enforcement, analyzing campus parking utilization and managing the parking programs at CMU. CMU Police Department may use LPR data in the response to immediate or ongoing safety concerns, conducting criminal investigations, and other compulsory law enforcement activities. As such, personally identifiable LPR data is accessible only by limited parties, including CMU Parking Services/CMU Police staff, their agents and vendors, and the OIT personnel that maintain the data, websites, and LPR infrastructure.

LPR data may be subject to aggregate data analysis and reported for approved departmental needs within CMU for planning, research, and educational purposes. No identifiable information will be contained in the reports. CMU Police may release LPR data when requested by external law enforcement agencies in response to exigent or emergency situations involving immediate danger of death or serious bodily injury. Requests for LPR data from external law enforcement agencies for non-emergency criminal investigations will be subject to review by CMU Police administration and CMU General Counsel prior to release. Data may be subject to release as otherwise required by law.

Any use of LPR data outside of these stated purposes must be detailed documented and approved in writing by the CMU Chief of Police.

Data retention

Metadata collected by the LPR system that does not result in a parking enforcement action and is not part of an ongoing law enforcement investigation will be purged after 365 days. LPR images collected by the LPR system that does not result in a parking enforcement action and is not part of an ongoing law enforcement investigation will be purged after 30 days. Metadata and images that result in parking enforcement action will be retained with the citation record until it is purged from the system. Metadata and images associated with an ongoing law enforcement investigation shall be retained with the investigative record according to established record retention policies and state law.

Access to records

Access to records created and maintained by the LPR system is restricted to trained CMU Police/Parking Services staff. All staff with access to the system shall use unique identifiers and passwords to access records and all login activity, record additions, and other activity is logged. Access to the system by others is prohibited.

Public notification

CMU will notify the public of its LPR data collection activities and policies by posting and updating this policy on the CMU Police/Parking Services website.

Last update: 6/1/2022