California Usage and Privacy Policy
This California Usage and Privacy Policy (“Policy”) governs the Automated License Plate Recognition System operated by NBCUniversal (“NBCU”) to secure its parking areas in the State of California (“ALPR system”). It describes how NBCU collects, uses, maintains, shares, and disseminates ALPR data from the ALPR system consistent with applicable law.
NBCU's ALPR system is a searchable computerized database resulting from the operation of one or more mobile or fixed cameras 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 ALPR system (“ALPR data”) includes still images of the backside of vehicles including license plates, plus the date and time when the images were collected, and the license plate characters and numbers associated with the image.
1. Collection, Use and Disclosure of ALPR Data
NBCU's ALPR system gathers ALPR data from vehicles entering and navigating within NBCU parking areas, processes it, and stores it on local servers. ALPR data is accessed and used solely for the following purposes:
- Detecting unauthorized vehicles;
- Securing NBCU properties;
- Preventing, responding to, and investigating reports of potential criminal, unauthorized or improper activity including potential violations of NBCU policies, and
- Operating and troubleshooting the ALPR system, security cameras, and network video recorders.
NBCU may disclose ALPR data to law enforcement or in response to a valid judicial process, such as in connection with:
- Investigating suspected crimes: identifying stolen, wanted, and subject of investigation vehicles; identifying individuals subject to arrest warrants or otherwise sought by law enforcement; and identifying witnesses and victims of violent crime.
- Identifying missing persons.
- Obtaining evidence for criminal prosecutions.
- Obtaining evidence for civil actions.
NBCU may also disclose ALPR data to its authorized service providers, such as security contractors and technical support providers that help maintain the ALPR system.
2. Authorized Users of the ALPR System
Only employees and contractors who have a business need to access the ALPR system or ALPR data are permitted to do so. Law enforcement agencies cannot collect or access ALPR data directly.
All NBCU employees or contractors who are provided access to the ALPR system or ALPR data are required to acknowledge that they have read and understood this Policy prior to using the ALPR system.
3. Training
NBCU trains its employees and contractors who have a business reason to interact with ALPR data on the sensitivity of ALPR data and the procedures that NBCU has put in place to protect it. Such training is conducted on an annual basis. In addition, all new employees who will have access to ALPR data receive training during employee onboarding.
Training content includes privacy protections for ALPR data, current NBCU policy regarding appropriate use of the ALPR system, ALPR technological capabilities and associated risks, and ALPR data security measures.
4. Monitoring and Compliance
NBCU maintains usage logs, and periodically audits such logs, to ensure the security of the ALPR system and compliance with this Policy.
5. Sale, Sharing or Transfer of ALPR Data
NBCU collects ALPR data for the purposes set forth in Section 1 above and does not collect data on behalf of law enforcement agencies. NBCU does not use, disclose, transfer, or sell ALPR data except as set forth in this Policy.
6. Custodian or Owner of the ALPR System
NBCU is the custodian and owner of the ALPR system and is responsible for implementing this Policy.
7. Accuracy of ALPR Data
NBCU will take reasonable measures to ensure the accuracy of ALPR data generated by the ALPR system, but cannot guarantee 100% accuracy. Should it be deemed necessary by NBCU, NBCU will check to confirm that the plate characters matched by the ALPR system correspond with the digital image of the license plate in question. Further, should it be deemed necessary by NBCU, NBCU will aim to correct mistaken translations and other database errors if those errors are identified and confirmed.
In the rare event that ALPR data is collected in violation of this Policy, that ALPR data will be purged upon identification.
8. Security
NBCU will use reasonable organizational and technical measures designed to protect ALPR data. The Internet and our services are not 100% secure, however, so complete security of the ALPR system is not guaranteed.
9. Retention
ALPR data is deleted after thirty (30) days, unless subject to a preservation request, subpoena, search warrant, or court order, or retained in connection with an investigation, claim or potential claim, in which case such retained ALPR data is handled in accordance with applicable NBCU policies.
10. Revisions of California Usage and Privacy Policy
NBCU reserves the right to revise this Policy to address changes in data sources, technology, data use and/or sharing agreements, and other relevant considerations.
Last Updated December 14, 2023
