This policy governs the Automated License Plate Recognition (ALPR) system operated by the Lexington-Fayette Urban County Airport Board at Blue Grass Airport (Airport) and applies to all Airport personnel and others who have access to data collected by the ALPR system or use the ALPR system. The ALPR system utilizes cameras located at the entrance/exit of the Airport parking lots to capture and store digital images of license plates in order to create a ticketless parking system in conjunction with third-party vendors. The ALPR system creates a computerized database resulting from the data collected by the cameras, including license plate numbers as well as the date and time when the image was collected. All images and data collected by the ALPR system shall be for Airport use only and will be managed with appropriate safeguards to ensure proper access and maintain confidentiality in accordance with the Airport’s Privacy Policy. 

Purpose: The purpose of this policy is to define the Airport’s appropriate use, maintenance, collection, security, and retention of all ALPR information, and the authorized users of the Airport’s ALPR system, in compliance with all applicable federal, state, and local laws. The Airport utilizes ALPR technology to capture, analyze, and store digital license plate data and images to enable the rapid identification of vehicles in support of parking operations and activities. ALPR shall supplement or replace paper tickets to log the times at which a vehicle enters or exits the Airport parking lot in order to determine the fee due upon exit.

Restricted Uses: The Airport only uses the ALPR system to collect license plate data within the Airport’s parking lots. The Airport does not use ALPR technology for the purpose of monitoring any other individual activities, in areas where there is a reasonable expectation of privacy or to harass, intimidate, or discriminate against any individual or group.

Authorizing Personnel and Training: All authorized users shall receive training prior to being granted access to the ALPR system. The training includes the proper use of the system prior to being granted access to an ALPR system. The training and ALPR policies shall be reviewed on an annual basis for updates, and refresher training may be provided, as needed.

Access: Authorized users with access to ALPR data shall include Airport staff with a need to specifically oversee such a system and/or are responsible for parking operations, as well as Airport-contracted third-party vendors.  All logins and queries are stored and monitored, and may contain the following information: (i) username; (ii) date; (iii) time; and (iv) purpose of query. This data shall be stored and monitored to ensure that the ALPR data is not accessed by unauthorized individuals. The Airport may run audits to ensure access to the data was only made by authorized persons for authorized uses.

Information Collected: The following information may be collected by the ALPR system: (i) license plate image and number; (ii) license plate state; and (iii) date and time.

Information Stored & Data Retention: ALPR data shall be sent to and stored in the third-party ALPR vendor’s database. The database stores license plate numbers of Airport customers entering and exiting the Airport’s parking lot. This information is used by the ALPR system to allow customers to gain entry and exit to the Airport parking lot without the need for a paper ticket. Routine data collection for Airport parking shall not be stored beyond 60 days. After the aforementioned retention times elapse, the third-party ALPR vendor shall automatically purge routine data records. The data records stored on the ALPR server include photographs of a portion of the vehicle and accompanying license plate number, date, time, and location in the field; such records do not include any personally identifiable information.

Security: The Airport and third-party ALPR vendor shall use appropriate administrative, operational, technical, and physical safeguards to protect ALPR information from unauthorized access, use, destruction, modification or disclosure.

Quality Assurance: Collection of ALPR is automated, so the license plate images and details of collection are included in the system without review. Although infrequent, license plate translation may be incomplete or inaccurate. The Airport and its third-party parking vendor shall attempt to ensure accuracy and correct license plate translation errors when identified.

Releasing ALPR Data: The Airport does not share ALPR data with anyone or private entity, other than third-party parking and ALPR vendors, as necessary to conduct Airport parking operations. Airport includes confidentiality provisions in its agreements with any parking contractors and/or vendors to prohibit any use or distribution of ALPR information for any purpose other than the authorized uses under this Policy. Airport shall provide ALPR data to a federal, state, or local law enforcement agency or any other public agency only if a warrant or other court order is issued and served. In addition, information gathered shall not be disclosed to the public or in a civil matter unless such disclosure is required by law or court order.

Enforcement: Violation of this Policy by an Airport employee, contractor, or other authorized user, may lead to suspension or termination of that user’s access to the ALPR system.