Dear Auckland Transport,

This is a request for official information under the Local Government Official Information and Meetings Act 1987.
I am requesting information regarding the scheme that uses vehicles equipped with Automated Number Plate Recognition (ANPR) cameras for parking enforcement (commonly referred to as "camera cars").
To assist with the processing of this request, I have broken it down into specific questions:
1. Authorising Documents and Decisions:
Please provide copies of the formal documents that authorised the implementation and rollout of the ANPR parking enforcement scheme. This includes, but is not limited to:
a) The minutes of any Council or Auckland Transport board meetings where the decision to approve the scheme was made.
b) The final version of any business case, proposal, or options analysis paper that was presented to decision-makers.
2. Legal and Privacy Advice:
Please provide copies of any legal advice, privacy impact assessments (PIAs), or similar advisory documents that were commissioned or created to assess the legality and privacy implications of the ANPR scheme before its implementation.
3. Operational Policies and Procedures:
Please provide the current operational policy, procedure, or training documents that govern:
a) How the ANPR system identifies and flags a potential parking infringement.
b) The process for human review of a flagged infringement before an infringement notice is issued.
c) The criteria an operator or reviewer uses to confirm or dismiss a machine-flagged event.
4. Data Handling and Retention:
Please provide the specific policy or documentation that outlines:
a) The retention period for ANPR data for vehicles that are not flagged for an infringement.
b) The retention period for ANPR data and associated images for vehicles that are issued an infringement notice.
c) A list of all third-party organisations or vendors who have access to the raw or processed ANPR data, and a copy of the data-sharing agreement or relevant privacy clauses in the contract with the primary vendor.
5. Statutory Authority:
Please identify the specific section(s) of the Land Transport Act 1998 or other relevant legislation that provides the statutory authority for an automated camera system to be the basis for issuing a parking infringement notice, particularly in relation to any requirement for an infringement to be issued by an "authorised officer" or "parking warden."
I request that this information be provided in a digital format.
If any part of this request is to be refused, please provide the specific grounds for refusal under LGOIMA and, as required by the Act, consider whether releasing a summary or an excerpt of the information is possible.
This request is made in the public interest to understand the legal and privacy framework of automated enforcement technologies being deployed in public spaces.

Yours faithfully,

Charlie Drummond

Dear AT Official Information (AT),

Many thanks, this response satisfies the original request.

Upon reviewing the material supplied, I would like to make a subsequent official information request for the following;

In the appendix D - the SOP for enforcement activities - in section 1 it states;

Enforcement map
Officers are required to check the enforcement map of their enforcement zone prior to leaving the office.
This requirement is to acquaint them with all the information pertaining to that zone.
Enforcement maps are in fleet vehicle’s box or see LPR teams under GENERAL – FILES.

Please provide a copy of all current enforcement maps used by the council.

Yours sincerely,

Charlie Drummond

Dear AT Official Information (AT),

This is a separate follow-on request arising from Auckland Transport's response of 27 January 2026 to my request of 21 November 2025 (reference CAS-1237699-H6H6V6).

Under the Local Government Official Information and Meetings Act 1987, I request the following:

1. Any Privacy Impact Assessment (PIA), privacy risk assessment, or equivalent document prepared in connection with the Licence Plate Recognition Vehicle Mounted Enforcement (LPR VME) system, at any stage of its development, trial, or ongoing operation.

2. If no such document exists, written confirmation of that fact.

3. Any document recording a decision that a PIA was not required for the LPR VME system, and the reasons for that decision.

Challenge to the Previous Withholding

In your response of 27 January 2026, Auckland Transport withheld "legal and privacy advice" relating to the LPR VME system under s7(2)(g) of the LGOIMA (legal professional privilege). I am not seeking to revisit that withholding in respect of legal advice. However, I note that no Privacy Impact Assessment was provided, and I am not satisfied that a PIA - if one exists - is properly withheld under s7(2)(g).

A PIA is not legal advice

Legal professional privilege under s7(2)(g) protects confidential communications between solicitor and client made for the purpose of giving or receiving legal advice. A Privacy Impact Assessment is an operational governance document. It is a structured assessment of the privacy risks posed by a system and the measures taken to mitigate them. It is produced to satisfy the requirements of the Privacy Act 2020 and to demonstrate organisational accountability, not to obtain legal advice. The mere fact that a lawyer may have reviewed or contributed to a PIA does not bring the whole document within privilege.

The Ombudsman's guidance on s7(2)(g) makes clear that the essential question is whether the document "was brought into existence for the purpose of getting or giving confidential legal advice or assistance" (Re Merit Finance and Investment Group). A PIA is brought into existence to assess privacy risk and demonstrate compliance. It is not privileged on that basis.

The public interest in disclosure is strong

Even if Auckland Transport were to contend that any PIA is partially privileged, s7(1) of the LGOIMA requires that the interest in withholding be weighed against the public interest in disclosure. I submit that the public interest in disclosure of a PIA for the LPR VME system is particularly strong for the following reasons.

First, the LPR VME system involves the systematic, mobile capture of continuous video footage and number plate data from every vehicle parked on public streets across designated areas of Auckland. This is not incidental capture at a fixed point; it is a deliberate, wide-area surveillance sweep of residential and commercial neighbourhoods. The scale of data collection from non-offending citizens is substantial.

Second, Auckland Transport's own CCTV Policy 2025 (effective 15 December 2025) confirms that ANPR metadata - including number plate, timestamp, and location - is retained for three years, even where no infringement is issued. This means the movements of compliant citizens are recorded and stored for three years without their knowledge or consent, and without any publicly available assessment of whether that retention is proportionate or necessary.

Third, the Business Requirements document for the LPR VME system (Appendix C, V1.0 Final) explicitly identifies privacy risk as a concern, noting that "images not constrained to licence plates and vehicles may violate a person's privacy" and that the survey/analytics function "may breach privacy policies." These risks were identified in 2016. The public has a legitimate interest in knowing whether those risks were ever formally assessed and what mitigations, if any, were put in place.

Fourth, the system has been in operation since at least 2016 and has been progressively expanded. The Privacy Act 2020 — which replaced the Privacy Act 1993 — introduced a strengthened accountability principle requiring agencies to take active steps to protect personal information. The public interest in knowing whether Auckland Transport has met that obligation in respect of a mass surveillance system is high.

Fifth, transparency about privacy governance is itself a public interest consideration recognised by the Ombudsman. The public interest in the accountability of public bodies for decisions affecting the rights of citizens is a well-established factor favouring disclosure.

Request for Urgency

I note that the CCTV Policy 2025 was approved on 20 November 2025 and came into effect on 15 December 2025. The question of whether Auckland Transport has ever conducted a proportionality assessment for the LPR VME system is therefore a live and current governance question. I request that this matter be treated with appropriate urgency.

Yours sincerely,

Charlie Drummond