Folkestone & Hythe District Council have 26 car park where customers have to pay. In 2019/20 all car parks brought in £1,377,657 according to Council data. In 2020/21, the car park income dropped to £992,512, a fall of 28%, or £385,145. The reason for the 28% fall in income was Covid. However, in 2021/22 the income across district car parks rose to £1,528,333, in part due to price increases, plus the return of visitors. What the council data for 2021/22, shows is six out of ten drivers are using cashless payments via the Ringo app (contactless payment) favored by the Council, as the data below shows. Cash payments will though remain an option.
But what is strange about this data is that it does not appear to follow Benford’s Law.
Benford’s Law is a way of detecting possible fraud. It maintains that the numeral 1 will be the leading digit in a genuine data set of numbers 30.1% of the time; the numeral 2 will be the leading digit 17.6% of the time; and each subsequent numeral, 3 through 9, will be the leading digit with decreasing frequency. But this does not appear to be the case with the Council’s data, as set out above.
There may be other reasons that the Council’s data doesn’t follow Benford’s law as it is a small data set, and other reasons, as can be read and understood ⇒ here
That aside, the Council now wish to move to more machines in car parks which accept contactless payment, as the data shows that 60% of drivers use contacless payments and lower’s the possibility of theft and fraud. The council will not be phasing out cash payments. There are 60 coin only pay machines and the cost to upgrade 35 of them will cost £27,000. The remaining 25 are too old to be upgraded. But 5 of these will be replaced by 2023 at a cost of £20,000.
But the story doesn’t just stop there.
The Council wish to introduce Automatic Number Plate Recognition (ANPR) technology in there car parks. ANPR allows cameras to identify and record the vehicle number plate as the motorist approaches the car park.
In Report Number C/21/105 the council make clear that not all car parks are suitable for ANPR due to difficulties with access. “Another challenge is the huge capital outlay (£40k – ~£100k) per car park.” However, some car parks that do not generate significant revenue, as such these are not suitable for this level of investment. Of the twenty six car parks across the district the council have identified seventeen could benefit from the installation of ANPR technolgy.
Sandgate Road car park has been identified as the most suitable car park for an ANPR system according to the Council, due to it having clearly defined entry/exit points, and significant annual revenues. Officers have sought quotations for ANPR to be installed in this car park. The total costs quoted for this project is £41k. Officers believe the introduction of ANPR in this car park will certainly be worth the investment.
ANPR is all about obtaining data… license plate data that is. GDPR law makes it very clear that signage must be visible to all persons if ANPR cameras are in place. So it would mean that the council would also have to update all signage across their car parks to ensure that all signage made it clear ANPR is in use. To upgrade the signage would cost money, but this is not included in the report. As such the £41k is not the true reflection of the whole cost to upgrade Sandgate Road car park.
ANPR is, fundamentally, the collection of consumer data. Specifically speaking, it is consumer vehicle data. While some may believe that having our Council know how long you spent in a car park within the district is no big deal, others may view this to be an outright invasion of their privacy. Why does the council need this information? With this in mind, GDPR rules apply to ANPR as it provides basic protections to consumers and gives them the right to privacy. Given the Council’s poor history with data protection, we – The Shepway Vox TEAM – have concerns. We hope that any installation of GDPR will comply with updating the signage, and we hope a full data impact assessment will be carried out prior to its installation.
The Shepway Vox Team
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