ANPR tracking - memorandum of understanding with the Police for disclosure of license plate hits
M B made this Official Information request to Auckland Transport
The request was successful.
From: M B
Dear Auckland Transport,
1. Please provide a copy of the memorandum of understanding between the Police and Auckland Transport related to the disclosure of ANPR data stored indefinitely.
2. Please provide any privacy assessments, risk assesments, correspondence with the Office of the Privacy Commissioner or any other privacy agency, related to your (indefinite) ANPR data retention period.
3. What company stores the ANPR data and where is it stored geographically? (Australia?)
4. What other companies or agencies have access to the ANPR data?
5. Provide all correspondence with the Police surrounding the initial agreement to provide data on the basis of a memorandum of understanding.
Yours faithfully,
Mason
From: AT Official Information (AT)
Auckland Transport
Kia ora Mason,
Auckland Transport (AT) acknowledges receipt of your request for official
information dated the 30^th of September 2022 relating to licence plate
recognition data.
We hope to respond to your request as soon as possible, but not later than
the 31^st of October 2022, which is 20 working days after the day your
request was received. If we aren’t able to respond to your request by
then, we will notify you of an extension of that timeframe.
Your case is being managed by Anna, who is one of our LGOIMA Business
partners. If you have any further queries, you can contact the team on
(09) 355 3553 during business hours, quoting Local Government Official
Information request number CAS-630855-V1W9W5.
Ngâ mihi,
Peter | Customer Care Coordinator
Customer Care| Case Management
Level 5, 20 Viaduct Harbour Avenue, Auckland 1010
P 09 355 3553
[1]www.at.govt.nz
From: M B <[FYI request #20718 email]>;
Received: Fri Sep 30 2022 18:57:46 GMT+1300 (New Zealand Daylight Time)
To: [email address] <at[Auckland Transport request email]>;
LGOIMA <at[Auckland Transport request email]>;
Subject: Official Information request - ANPR tracking - memorandum of
understanding with the Police for disclosure of license plate hits
Dear Auckland Transport,
1. Please provide a copy of the memorandum of understanding between the Police and Auckland Transport related to the disclosure of ANPR data stored indefinitely.
2. Please provide any privacy assessments, risk assesments, correspondence with the Office of the Privacy Commissioner or any other privacy agency, related to your (indefinite) ANPR data retention period.
3. What company stores the ANPR data and where is it stored geographically? (Australia?)
4. What other companies or agencies have access to the ANPR data?
5. Provide all correspondence with the Police surrounding the initial agreement to provide data on the basis of a memorandum of understanding.
Yours faithfully,
Mason
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show quoted sections
From: AT Official Information (AT)
Auckland Transport
Kia ora M
We need a bit more time to work on your case.
My name is Anna and I’m a LGOIMA Business Partner at Auckland Transport.
We are granting your request which means we hold the information you have
requested and we will provide it.
We are in the process of gathering the information and it will take us a
little bit longer to prepare the information for release.
We estimate the information will be ready by 11 November 2022.
Please let us know if you would like to discuss the decision.
You have the right to seek an investigation and review by the Ombudsman of
this decision. Information about how to make a complaint is available at
[1]www.ombudsman.parliament.nz or freephone 0800 802 602.
Anna
LGOIMA Business Partner
Auckland Transport
20 Viaduct Harbour Avenue, Auckland 1010
[2]www.at.govt.nz
We all have an important part to play in helping to reduce the spread of
COVID-19 in our communities. [3]Find the latest information and advice
from Auckland Transport. For the latest news from the Ministry of Health
go to the [4]Unite Against Covid-19 website.
Important notice: The contents of this email and any attachments may be
confidential and subject to legal privilege. If you have received this
email message in error please notify us immediately and erase all copies
of the message and attachments; any use, disclosure or copying of this
message or attachments is prohibited. Any views expressed in this email
may be those of the individual sender and may not necessarily reflect the
views of Auckland Transport.
References
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2. http://www.at.govt.nz/
3. https://at.govt.nz/COVID-19
4. https://covid19.govt.nz/
From: AT Official Information (AT)
Auckland Transport
Auckland Transport CAS 630855 V1W9W5 ANPR follow up Police MOU.pdf
337K
Download
View as HTML
LGOIMA CAS 630855 V1W9W5 AT Police MOU.pdf
550K
Download
View as HTML
Kia ora Mason
I’ve attached the official information you asked for
On 30/09/2022 you asked information relating to ANPR tracking - memorandum
of understanding with the Police for disclosure of license plate hits.
I’ve attached a response from Roger Jones, Executive General Manager
Business Technology.
Should you believe that we have not dealt with your request appropriately,
you are able to make a complaint to the Office of the Ombudsman in
accordance with section 27(3) of the LGOIMA Act and seek an investigation
and review in regard to this matter.
You can contact the Ombudsman at [1]www.ombudsman.parliament.nz or
freephone 0800 802 602.
If you have any further queries, simply reply to this email leaving the
subject line as it is. We’ll make sure this information is added to your
case.
Ngā mihi
Anna
LGOIMA Business Partner
Auckland Transport
20 Viaduct Harbour Avenue, Auckland 1010
[2]www.at.govt.nz
We all have an important part to play in helping to reduce the spread of
COVID-19 in our communities. [3]Find the latest information and advice
from Auckland Transport. For the latest news from the Ministry of Health
go to the [4]Unite Against Covid-19 website.
Important notice: The contents of this email and any attachments may be
confidential and subject to legal privilege. If you have received this
email message in error please notify us immediately and erase all copies
of the message and attachments; any use, disclosure or copying of this
message or attachments is prohibited. Any views expressed in this email
may be those of the individual sender and may not necessarily reflect the
views of Auckland Transport.
References
Visible links
1. file:///tmp/www.ombudsman.parliament.nz
2. file:///tmp/www.at.govt.nz
3. https://at.govt.nz/COVID-19
4. https://covid19.govt.nz/
From: M B
Dear AT Official Information (AT),
I don't think this requires a fresh OIA, could you please clarify one point of your response.
You state that ANPR data is only held for 7 days and only "anonymised ANPR data" is retained indefinitely, "this means that no individual, person or otherwise is identifiable".
What is done to anonymised the data?
Yours sincerely,
Mason.
From: AT Official Information (AT)
Auckland Transport
Good morning Mason,
We use AES-256 encryption algorithms to encrypt licence plate numbers and
all other attributes for data that is not used for enforcement related
purposes, which is one of the strongest encryption standards available.
Kind regards
Anna
From: M B <[FOI #20718 email]>;
Received: Fri Nov 04 2022 13:34:17 GMT+1300 (New Zealand Daylight Time)
To: [email address] <at[Auckland Transport request email]>;
LGOIMA <at[Auckland Transport request email]>;
Subject: Re: Here’s the official information you asked for (case number
CAS-630855-V1W9W5 ) CRM:0134]8
Dear AT Official Information (AT),
I don't think this requires a fresh OIA, could you please clarify one point of your response.
You state that ANPR data is only held for 7 days and only "anonymised ANPR data" is retained indefinitely, "this means that no individual, person or otherwise is identifiable".
What is done to anonymised the data?
Yours sincerely,
Mason.
show quoted sections
J. Beddek left an annotation ()
"We use AES-256 encryption algorithms". I assume they're hashing the data with something like sha256sum although encryption implies the use of a known private key somewhere along the way.
"encrypt licence plate numbers and all other attributes for data"
I wonder if they hash all the data at once or hash different fields like date, time, location etc. If it's the latter reversing the sums would be easy through brute forcing the small number of possible combinations (e.g. date/time).
I'm also not entirely sure how encryption of the data relates to anonymization. If the content of the data isn't available due to encryption, what use is it?
From: M B
Hi Anna,
As one user on FYI identified in the short period since your response, I am at a loss as to how encryption of license plate data would anonymise it if you held the encryption key. Could you please expand on your answer and provide a reference to what Auckland Transport considers to be Anonymised ANPR data?
Perhaps an example an incoming and outgoing license plate would assist.
If so desired, would Auckland Transport be able to de-"anonymise" the data via their encryption key?
Yours sincerely,
Mason.
From: AT Official Information (AT)
Auckland Transport
Kia ora Mason,
Auckland Transport (AT) acknowledges receipt of your request for official
information dated the 11^th of November 2022 relating to anonymised
licence plate recognition data.
We hope to respond to your request as soon as possible, but not later than
the 9^th of December 2022, which is 20 working days after the day your
request was received. If we aren’t able to respond to your request by
then, we will notify you of an extension of that timeframe.
Your case is being managed by Anna, who is one of our LGOIMA Business
partners. If you have any further queries, you can contact the team on
(09) 355 3553 during business hours, quoting Local Government Official
Information request number CAS-647451-C0J1C3.
Ngā mihi,
Peter | Customer Care Coordinator
Customer Care| Case Management
Level 5, 20 Viaduct Harbour Avenue, Auckland 1010
P 09 355 3553
[1]www.at.govt.nz
From: M B <[FYI request #20718 email]>;
Received: Fri Nov 11 2022 02:29:59 GMT+1300 (New Zealand Daylight Time)
To: [email address] <at[Auckland Transport request email]>;
LGOIMA <at[Auckland Transport request email]>;
Subject: Re: FW: Re: Here’s the official information you asked for (case
number CAS-630855-V1W9W5 ) 4~<
Hi Anna,
As one user on FYI identified in the short period since your response, I am at a loss as to how encryption of license plate data would anonymise it if you held the encryption key. Could you please expand on your answer and provide a reference to what Auckland Transport considers to be Anonymised ANPR data?
Perhaps an example an incoming and outgoing license plate would assist.
If so desired, would Auckland Transport be able to de-"anonymise" the data via their encryption key?
Yours sincerely,
Mason.
show quoted sections
From: AT Official Information (AT)
Auckland Transport
CAS 647451 C0J1C3 ANPR Decryption Process.pdf
250K
Download
View as HTML
CAS 647451 C0J1C3 Mason ANPR Decryption Process.pdf
314K
Download
View as HTML
Kia ora Mason
I’ve attached the official information you asked for
On 11/11/2022 you asked for information relating to ANPR data.
I’ve attached a response from Roger Jones, Exec GM Business Technology.
Should you believe that we have not dealt with your request appropriately,
you are able to make a complaint to the Office of the Ombudsman in
accordance with section 27(3) of the LGOIMA Act and seek an investigation
and review in regard to this matter.
You can contact the Ombudsman at [1]www.ombudsman.parliament.nz or
freephone 0800 802 602.
If you have any further queries, simply reply to this email leaving the
subject line as it is. We’ll make sure this information is added to your
case.
Ngā mihi
Anna
LGOIMA Business Partner
Auckland Transport
20 Viaduct Harbour Avenue, Auckland 1010
[2]www.at.govt.nz
We all have an important part to play in helping to reduce the spread of
COVID-19 in our communities. [3]Find the latest information and advice
from Auckland Transport. For the latest news from the Ministry of Health
go to the [4]Unite Against Covid-19 website.
Important notice: The contents of this email and any attachments may be
confidential and subject to legal privilege. If you have received this
email message in error please notify us immediately and erase all copies
of the message and attachments; any use, disclosure or copying of this
message or attachments is prohibited. Any views expressed in this email
may be those of the individual sender and may not necessarily reflect the
views of Auckland Transport.
References
Visible links
1. file:///tmp/www.ombudsman.parliament.nz
2. file:///tmp/www.at.govt.nz
3. https://at.govt.nz/COVID-19
4. https://covid19.govt.nz/
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Mark Hanna left an annotation ()
"I don't think this requires a fresh OIA"
Just so you're not surprised if AT puts your follow-up question through their regular OIA process, any request for official information received by a government agency automatically qualifies as a request under the OIA, and all the protections it gives such as being told any reasons why information wasn't released. It doesn't matter how the request is made, or if the OIA is mentioned.
There is no way to opt out of this, though there are of course ways agencies can streamline the process for small or straightforward requests.
If it would be reasonably practicable for AT to respond to your follow-up question quickly, well, communicating their decision as soon as reasonably practicable is a requirement of the OIA.
Link to this